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Modern Slavery Act
The 2016 Global Slavery Index estimates that 45.8 million people are subject to some form of modern slavery in the world, and in the UK alone the survey estimates 11,700 victims of slavery. To help tackle this issue the UK Government introduced the Modern Slavery Act in October 2015. LL Plastic Ltd has a zero-tolerance approach to slavery and human trafficking. The policies we have in place along with our Anti-Slavery and Human Trafficking statement reflect our commitment to:
- Act ethically and with integrity in all our business relationships.
- Enforce effective systems and controls to prevent slavery and human trafficking in our corporate activities ensuring that our supply chains are free from slavery and human trafficking.
- Pay people fairly and properly for their work.
Anti-Corruption and Bribery Policy
Policy statement
It is the policy of LL Plastic Ltd (the Firm) to conduct business in an honest and ethical manner. As part of that, the Firm takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships, wherever it operates, and implementing and enforcing effective systems to counter bribery.
Purpose
The Firm will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which it conducts business, including, in the UK, the Bribery Act 2010 (the Act), which applies to conduct both in the UK and abroad.
Scope and applicability
This policy applies to all individuals working for or on behalf of the Firm at all levels and grades, whether permanent, fixed-term or temporary, and wherever located, including consultants, contractors, seconded staff, casual staff, agency staff, volunteers, agents, sponsors and any other person who performs services for or on behalf of the Firm, (collectively referred to as Workers in this policy).
In this policy, Third Party means any individual or organisation that Workers come into contact with during the course of work and the running of the Firm’s business, and includes actual and potential clients, intermediaries, referrers of work, suppliers, distributors, business contacts, agents, advisers, government and public bodies (including their advisers, representatives and officials), politicians and political parties.
What is bribery?
A bribe is an inducement or reward offered, promised or provided in order to improperly gain any commercial, contractual, regulatory or personal advantage, which may constitute an offence under the Act, namely:
• giving or offering a bribe;
• receiving or requesting a bribe; or
• bribing a foreign public official.
The Firm may also be liable under the Act if it fails to prevent bribery by an associated person (including, but not limited to Workers) for the Firm’s benefit.
Gifts and hospitality
This policy does not prohibit normal and appropriate gifts and hospitality (given and received) to or from Third Parties unless otherwise specifically stated. However, we have specific internal policies and procedures which provide guidance to Workers as to what is to be regarded as normal and appropriate gifts and hospitality in terms of financial limits, subject to the principles set out below (the Overriding Principles), namely that any gift or hospitality:
• must not be made with the intention of improperly influencing a Third Party or Worker to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
• must comply with local law in all relevant countries;
must be given in the name of the organisation, not in an individual’s name;
• must not include cash or a cash equivalent;
• must be appropriate in the circumstances;
• must be of an appropriate type and value and given at an appropriate time taking into account the reason for the gift;
• must be given openly, not secretly; and
• in the case of gifts, they must not be offered to, or accepted from, government officials or representatives, politicians or political parties, without the prior approval of either the Firm’s Directors
The Firm appreciates that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable both in the UK and any other relevant country. The intention behind the gift should always be considered.
What is not acceptable?
It is not acceptable for any Worker (or someone on their behalf) to:
• give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that they or the Firm will improperly be given a business advantage, or as a reward for a business advantage already improperly given;
• give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to facilitate or expedite a routine procedure;
• accept payment from a Third Party where it is known or suspected that it is offered or given with the expectation that the Third Party will improperly obtain a business advantage;
• accept a gift or hospitality from a Third Party where it is known or suspected that it is offered or provided with an expectation that a business advantage will be improperly provided by the Firm in return;
• threaten or retaliate against another Worker who has refused to commit a bribery offence or who has raised concerns under this policy; or
• engage in any activity that might lead to a breach of this policy.
Facilitation payments and “kickbacks”
We do not make, and will not accept, facilitation payments or “kickbacks” of any kind, such as small, unofficial payments made to secure or expedite a routine government action by a government official, or payments made in return for a business favour or advantage.
Charitable Donations and Sponsorship
The Firm only makes charitable donations and provides sponsorship that are legal and ethical under local laws and practices and which are in accordance with the Firm’s internal policies and procedures.
Record keeping
We keep appropriate financial records and have appropriate internal controls in place which evidence the business reason for gifts, hospitality and payments made and received.
Responsibilities and raising concerns
The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All Workers are required to avoid any activity that might lead to, or suggest, a breach of this policy
Workers are required to notify the Firm as soon as possible if it is believed or suspected that a conflict with this policy has occurred, or may occur in the future, or if they are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that they are a victim of another form of unlawful activity.
Any employee who breaches this policy may face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with non-employee Workers if they breach this policy.
If any Third Party is aware of any activity by any Worker which might lead to, or suggest, a breach of this policy, they should raise their concerns with any of the Firm’s Directors on 0742 760 2213.
Training and communication
Training on this policy is provided for all Workers and our zero-tolerance approach to bribery and corruption will, where appropriate, be communicated to clients, suppliers, contractors and business partners.
Monitoring and review
The Firm monitors the effectiveness and reviews the implementation of this policy at appropriate intervals, considering its suitability, adequacy and effectiveness. Any improvements identified are made as soon as possible. Internal control systems and procedures are also subject to regular review to provide assurance that they are effective in countering any risks of bribery and corruption.
All Workers are aware that they are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.
National Minimum Wage
All LL Plastic Ltd employees are ensured to be employed with the highest regard to fair pay in full compliance to The National Minimum Wage Act 1998 (“the 1998 Act”, as amended, including by the Employment Act 2008 Act (the “2008 Act”)) introduced a statutory right to be paid a certain amount of remuneration for work performed. Almost all workers in the UK are entitled to the National Minimum Wage or the National Living Wage. Workers are defined in Section 54 of the 1998 Act.
Sustainable and ethical supply chains
With 2 stores in the UK and hundreds of products available, we know that you trust us to make sure the products you love to buy are sourced responsibly and ethically. That’s why we’ve made it our priority to ensure that all LL Plastic products are produced by suppliers who treat their workers fairly and show a responsible attitude to the environment.
We work hard to make this happen, using our own in-house ‘supplier assessment’ and audit them against the LL Plastic ‘Code of Conduct for Ethical Trading’. We also use stringent policies and processes to make sure that our products meet the highest standards you expect.
Here are some examples of the systems we have in place to help us do this:
Supplier audit
Our in-house supplier assessment approved external partners based in the UK and abroad assess every LL Plastic product supplier against the LL Plastic ‘Code of Conduct for Ethical Trading’, ensuring they are working as hard as we do to protect their employees and the environment.
Our internal team holds regular reviews to meet and further engage our global supplier products in the standards our customers expect of any LL Plastic supplier.
Equal Opportunities
Statement of policy and purpose of policy:
1. LL Plastic Ltd (the Employer) is committed to equal opportunities for all staff and applicant.
2. It is our policy that all employment decisions are based on merit and the legitimate business needs of the organisation. The Employer does not discriminate on the basis of race, colour or nationality, ethnic or national origins, sex, gender reassignment, sexual orientation, marital or civil partner status, pregnancy or maternity, disability, religion or belief, age or any other ground on which it is or becomes unlawful to discriminate.
3. Our intention is to enable all our staff to work in an environment which allows them to fulfil their potential without fear of discrimination, harassment or victimisation. The Employer’s commitment to equal opportunities extends to all aspects of the working relationship including:
· Recruitment and selection procedures;
· Terms of employment, including pay, conditions and benefits;
· Training, appraisals, career development and promotion;
· Work practices, conduct issues, allocation of tasks, discipline and grievances;
· Work-related social events
· Termination of employment and matters after termination, including references.
4. This policy is intended to help the Employer achieve its diversity and anti-discrimination aims by clarifying the responsibilities and duties of all staff in respect of equal opportunities and discrimination.
5. The principles of non-discrimination and equal opportunities also apply to the way in which staff treat visitors, clients, customers, suppliers and former staff members.
6. This is a statement of policy only and does not form part of your contract of employment. This policy may be amended at any time by the Employer, in its absolute discretion.
Who is responsible for equal opportunities?
1. Achieving an equal opportunities workplace is a collective task shared between the employer and all its staff. This policy and the rules contained in it therefore apply to all staff of the Employer irrespective of seniority, tenure and working hours, including all employees, directors and officers, consultants and contractors, casual or agency staff, trainees, homeworkers and fixed-term staff and any volunteers or interns (referred to as Staff).
2. The CEO has overall responsibility for this policy and for equal opportunities and discrimination law compliance in the workplace and the CEO has been appointed as the person with day-to-day operational responsibility for these matters.
3. All Staff have personal responsibility to ensure compliance with this policy, to treat colleagues with dignity at all times and not to discriminate against or harass other members of Staff, visitors, clients, customers, suppliers and former staff members. In addition, Staff who take part in management, recruitment, selection, promotion, training and other aspects of career development (referred to as Managers) have special responsibility for leading by example and ensuring compliance.
4. Managers must take all necessary steps to:
· Promote the objective of equal opportunities and the values set out in this policy;
· Ensure that their own behaviour and those of the Staff they manage complies in full with this policy;
· Ensure that any complaints of discrimination, victimisation or harassment (including against themselves) are dealt with appropriately and are not suppressed or disregarded.
What is discrimination?
1. Discrimination occurs in different ways, some more obvious than others. Discrimination on the grounds of any of the Protected Characteristics is prohibited by law, even if unintentional, unless a particular exception applies.
2. Direct Discrimination is less favourable treatment because of one of the Protected Characteristics. Examples would include refusing a woman a job as a chauffeur because you believe woman are not good drivers or restricting recruitment to persons under 40 because you want to have a young and dynamic workforce.
3. Direct Discrimination can arise in some cases even though the person complaining does not actually possess the Protected Characteristic but is perceived to have it or associates with other people who do. For example, when a person is less favourably treated because the are (wrongly) believed to be homosexual.
4. Indirect Discrimination arises when an employer applies an apparently neutral provision, criterion or practise which in fact puts individuals with a particular Protected Characteristic at a disadvantage, statistically and this is unjustified. To show discrimination the individual complaining also has to be personally disadvantaged. An example would be a requirement for job candidates to have ten years’ experience in a particular role, since this will be harder for young people to satisfy. This kind of discrimination is unlawful unless it is a proportionate means of achieving a legitimate aim.
5. Victimisation means treating a person less favourably because they have made a complaint of discrimination or have provided information in connection with a complaint or because they might do one of these things.
6. Harassment is:
· Unwanted conduct which is related to a Protected Characteristic and which has the purpose or effect of violating a persons dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them
· Unwanted conduct which is of a sexual nature and which has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading or offensive environment for them (Sexual Harassment)
· Less favourable treatment because of the rejection of or the submission to Sexual Harassment.
7. Harassment can arise in some cases even though the person complaining does not actually possess a Protected Characteristic but is perceived to have it (for example, when a person is harassed because they are (wrongly) believed to be a homosexual) or associated with other people who possess a Protected Characteristic.
8. Harassment may include:
· Use of insults or slurs based on a Protected Characteristic or of a sexual nature or other verbal abuse or derogatory, offensive or stereotyping jokes or remarks,
· Physical or verbal abuse, threatening or intimidating behaviour because of a Protected Characteristic or behaviour of a sexual nature
· Unwelcome physical contact including touching, hugging, kissing, pinching or patting, brushing past, invading personal space, pushing, grabbing or other assaults;
· Mocking, mimicking or belittling a person’s disability, appearance, accent or other personal characteristics;
· Unwelcome requests for sexual acts or favours, verbal sexual advances, vulgar, sexual, suggestive or explicit comments or behaviour
· Repeated requests, either explicitly or implicitly, for dates,
· Repeated requests for social contact or after it has been made clear that requests are unwelcomes,
· Comments about body parts or sexual preference
· Displaying or distributing offensive or explicit pictures, items or materials relating to a Protected Characteristic or of a sexual nature
· Shunning or ostracising someone, for example, by deliberately excluding them from conversations or activities,
· Outing or threatening to out someone’s sexual orientation (i.e to make it known)
· Explicit or implicit suggestions that employment status or progression is related to toleration of, or acquiescence to sexual advances, or other behaviour amounting to harassment.
9. Other important points to note about harassment:
· A single incident can amount to harassment
· Behaviour that has continued for a long period without complaint can amount to harassment
· It is not necessary for an individual to intend to harass someone for their behaviour to amount to harassment
· It is not necessary for an individual to communicate that behaviour is unwelcome before it amounts to harassment
· The onus is on each individual to be certain that their behaviour and conduct is appropriate and is not unwanted and in the case of doubt, you must refrain from such conduct.
10. Disability Discrimination – This could be direct or indirect discrimination, and is any unjustified less favourable treatment because of the effects of a disability, and failure to make reasonable adjustments to alleviate disadvantages caused by a disability.
Disabled Persons
1. Any staff member who considers that they may have a disability is strongly encouraged to speak with the HR manager, particularly if they experience difficulties at work because of their disability so that any reasonable adjustments to help overcome or minimise difficulties can be discussed. For these purposes, disability includes any physical or mental impairment which substantially affects your ability to perform day to day activities and has lasted (or is likely to last) more than 12 months. Disclosure of this information will be treated in confidence, if you wish it to be, so far as is reasonably practicable and we will do our best to handle matters sensitively and to ensure that you are treated with dignity and with respect for your privacy.
2. We will consult with you about whether adjustments are needed to avid you being disadvantaged and may ask you to see a doctor appointed by us, to advise on this. We will seek to accommodate your needs within reason. If we consider a particular adjustment unreasonable we will explain why and try to find an alternative solution.
3. Managers with responsibility for managing a member of Staff who they know or think to be disabled should speak to the HR Manager to ensure that all relevant duties are complied with.
Making Employment Decisions Fairly
1. As noted above, the Employer will recruit employees and make other employment decisions concerning promotion, training, dismissal and related issues on the basis of objective criteria.
2. Managers should only stipulate criteria or conditions for employment decisions (including job selection, promotion and redundancy) which are based on legitimate business need and which do not go further than is needed to satisfy that need. If you are in any doubt about whether particular criteria or conditions are indirectly discriminatory or justifiable, then please speak to the HR Manager.
Recruitment
1. Managers involved in recruitment must:
· Specify only recruitment criteria that are relevant to the job, reflect genuine business needs and are proportionate. More than one person should be involved in shortlisting of applicants wherever practicable;
· Ensure that vacancies are advertised to a diverse audience and try to avoid informal recruitment methods that exclude fair competition. In very rare cases, it may be legitimate and necessary to restrict recruitment to a particular role to certain groups, but it is essential that this is discussed with the HR Manager so that appropriate steps can be taken to ensure legality;
· Review job advertisements carefully to ensure that stereotyping is avoided and that particular groups are not unjustifiably discouraged from applying;
· Not ask applicants about health or disability before a job offer is made (other than in exceptional circumstances and after having it approved by the HR Manager). If neccessary a job offer can be expressed to be conditional upon satisfactorily passing a medical check.
