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Company Policies


1. Purpose

The purpose of this policy is to establish controls to ensure compliance with all applicable anti-bribery regulations, and to ensure our business is conducted in a socially responsible manner. This policy applies to all the countries and territories that we as an organisation operates in.

This policy needs to be read alongside our related policies and procedures where appropriate. See Appendix ‘A’.


2. Policy statement

Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal or a breach of trust. A bribe is an inducement or reward offered, promised, or provided in order to gain any commercial, contractual, regulatory or personal advantage. It is our policy to conduct all our business in an honest and ethical manner. We take a zero- tolerance approach to bribery and corruption.

We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate, implementing, and enforcing effective systems to counter bribery. We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct both at home and abroad.

Bribery and corruption are punishable for individuals by up to ten years' imprisonment and a fine. If we are found to have taken part in corruption, we could face an unlimited fine, be excluded from tendering for public contracts and face damage to our reputation. We therefore take our legal responsibilities very seriously.

3. Scope

3.1 Who is covered by the policy?

In this policy, third party means any individual or organisation you meet during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians, and political parties. All arrangements with third parties should be subject to clear contractual terms, including specific provisions requiring them to comply with minimum


Reviewed by Audit Committee 7th December 2019

Standards and procedures in relation to bribery and corruption. Appropriate wording to be included in contracts can be obtained from the Legal team. This policy applies to all employees (whether permanent, fixed term or temporary), consultants, contractors, trainees, seconded staff, home

workers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as employees in this policy). It also applies to Officers, Trustees, Board and or Committee members and Members (any membership level)

This policy covers:

• Bribes.

• Gifts and hospitality.

• Facilitation payments

• Political contributions.

• Charitable contributions

3.2 Bribes

Employees must not engage in any form of bribery, either directly or through any third party (such as an agent or distributor). Specifically, employees must not bribe a foreign public official anywhere in the world.

3.3 Gifts and hospitality

Please see our Gifts Policy in the Employee Handbook.

3.4 Facilitation payments and kickbacks

Facilitation payments are a form of bribery made for the purpose of expediting or facilitating the performance of a public official for a routine governmental action, and not to obtain or retain business or any improper business advantage. Facilitation payments tend to be demanded by low level officials to obtain a level of service, which one would normally be entitled to. Our strict policy is that facilitation payments must not be paid. We recognise, however, that our employees may be faced with situations where there is a risk to the personal security of an employee or his/her family and where a facilitation payment are unavoidable, in which case the

following steps must be taken:


  • Keep any amount to the minimum.

  • Create a record concerning the payment.

  • Report it to your line manager.


Review due 7th December 2025

3.5 Political contributions We do not make donations, whether in cash or kind, in support of any political parties or candidates, as this can be perceived as an attempt to gain an improper business advantage.



3.6 Charitable contributions

Charitable support and donations are acceptable (and indeed are encouraged), whether of in- kind services, knowledge, time, or direct financial contributions. However, employees must be careful to ensure that charitable contributions are not used as a scheme to conceal bribery. We only make charitable donations that are legal and ethical under local laws and practices]. No donation on behalf of the organisation must be offered or made without the prior approval of a member of the Leadership Team.

4. Record-keeping

You must declare and keep a written record of all gifts accepted or offered, which will be subject to management review. You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses policy.


5. How to raise a concern

You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest Possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries or concerns, these should be raised with your line manager, director Head of Governance and Legal. If you feel you cannot raise it with any of the above, then please discuss with Stephane Delueze.

Audit Committee and refer to our Whistleblowing Policy.

6. What to do if you are a victim of bribery or corruption

It is important that you tell your line manager, director or the legal department as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.

Reviewed by Audit Committee 7th December 2019

7. Protection

Employees who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. 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. For further info, please view our Whistleblowing Policy

8. Training and communication

Training on this policy forms part of the induction process for all new employees, Members, and trustees. All existing employees receive regular, relevant training on how to adhere to this policy.

Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and as appropriate thereafter.

Please refer to the Bribery Act Statement – Appendix B



9. Who is responsible for the policy?

The Management Team has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The Audit Committee has general responsibility on

behalf of ICOR Ltd for monitoring the operation and effectiveness of our antibribery arrangements. Management and Legal has primary and day-to-day responsibility for implementing this policy and for dealing with any queries on its interpretation. Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it.

All employees are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing. This policy does not form part of any employee's contract of employment and it may be amended at any time.


10 Statement Appendix B

The Bribery Act 2010 is arguably the toughest anti-bribery regime in the world. The Act imposes criminal liability on individuals and organisations in the event that employees, subsidiaries, agents or consultants pay or accept bribes in relation to the organisation's business anywhere in the world.

The Leadership Team are committed to ensuring that the ICOR Ltd operates as an ethical organisation. Bribery or corruption in any form will not be tolerated. We expect our employees, stakeholders, members, and business partners to conduct business in a fair, honest and ethical manner at all times.

ICOR Ltd prohibits the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement to or from any person or company, wherever they are situated and whether they are a public official or body or private person or company.

By any individual employee, agent, member or other person or body acting on the ICOR Ltd behalf. in order to gain any commercial, contractual, or regulatory advantage in a way which is unethical. Or in order to gain any personal advantage, financial or otherwise, for the individual or anyone connected with the individual.

ICOR Ltd recognises that market practice varies across the territories in which we do business and what is normal and acceptable in one place may not be in another. This policy is not meant to prohibit the following practices providing they are customary in a particular market, are proportionate and are properly declared and recorded:

• normal and appropriate hospitality

• the giving of a ceremonial gift on a festival or at another special time

• use of any recognised fast-track process which is available to all on payment of a fee

• the offer of resources to assist a person or body to make a decision more efficiently,

provided that they are supplied for that purpose only.

Inevitably, decisions as to what is acceptable may not always be easy. If at any time you are in doubt as to whether a potential act constitutes bribery, the matter should be referred to a responsible person within ICOR Ltd.

The prevention, detection and reporting of bribery is the responsibility of each individual working on behalf of the ICOR Ltd. ICOR Ltd operates a zero-tolerance approach to any attempts at bribery by, 0r of, its employees and associated persons and encourages all such individuals to report any suspected bribery activity to a responsible person within ICOR Ltd. You will be fully supported if you make a report of suspected bribery in good faith even if, following an investigation, there is no finding that bribery took place.

In the event of any bribery activity being suspected, ICOR Ltd will carry out a full investigation and if any bribery activity is discovered, ICOR Ltd may:

• in relation to employees, invoke its disciplinary procedures, which could result in a finding

of gross misconduct and immediate dismissal, or

• in relation to members, refer the matter to the Disciplinary Committee. If you have any concerns or queries in relation to this statement or your obligations, please make

these known to a responsible person within ICOR Ltd.

ICOR Ltd data protection policy

ICOR Ltd known as the Company.

Our Company Data Protection Policy refers to our commitment to treat information of employees, customers, stakeholders and other interested parties with the utmost care and confidentiality.

With this policy, we ensure that we gather, store and handle data fairly, transparently and with respect towards individual rights.


This policy refers to all parties (employees, job candidates, customers, suppliers etc.) who provide any amount of information to us.

Who is covered under the Data Protection Policy?

Employees of our company and its subsidiaries must follow this policy. Contractors, consultants, partners and any other external entity are also covered. Generally, our policy refers to anyone we collaborate with or acts on our behalf and may need occasional access to data.

Policy elements

As part of our operations, we need to obtain and process information. This information includes any offline or online data that makes a person identifiable such as names, addresses, usernames and passwords, digital footprints, photographs, social security numbers, financial data etc.

Our company collects this information in a transparent way and only with the full cooperation and knowledge of interested parties. Once this information is available to us, the following rules apply.

Our data will be:

●         Accurate and kept up-to-date

●         Collected fairly and for lawful purposes only

●         Processed by the company within its legal and moral boundaries

●         Protected against any unauthorized or illegal access by internal or external parties

Our data will not be:

●         Communicated informally

●         Stored for more than a specified amount of time

●         Transferred to organizations, states or countries that do not have adequate data protection policies

●         Distributed to any party other than the ones agreed upon by the data's owner (exempting legitimate requests from law enforcement authorities)

In addition to ways of handling the data the company has direct obligations towards people to whom the data belongs. Specifically we must:

●         Let people know which of their data is collected

●         Inform people about how we'll process their data

●         Inform people about who has access to their information

●         Have provisions in cases of lost, corrupted or compromised data

●         Allow people to request that we modify, erase, reduce or correct data contained in our databases


To exercise data protection we're committed to:

●         Restrict and monitor access to sensitive data

●         Develop transparent data collection procedures

●         Train employees in online privacy and security measures

●         Build secure networks to protect online data from cyberattacks

●         Establish clear procedures for reporting privacy breaches or data misuse

●         Include contract clauses or communicate statements on how we handle data

●         Establish data protection practices (document shredding, secure locks, data encryption, frequent backups, access authorization etc.)

Our data protection provisions will appear on our website.

Disciplinary Consequences

All principles described in this policy must be strictly followed. A breach of data protection guidelines will invoke disciplinary and possibly legal action.


Disclaimer: This policy template is meant to provide general guidelines and should be used as a reference. It may not take into account all relevant local, state or federal laws and is not a legal document. Neither the author nor Workable will assume any legal liability that may arise from the use of this policy.


Further reading:

●         Data Protection Act of 1998 (UK)


We are committed to minimising the impact of our activities on the environment.


This statement covers activities of ICOR Ltd. The key points of its strategy to achieve this are:



Integrate environmental concerns into all planning and design decisions and maintenance and management of properties

Continually seek to measure and improve environmental performance

Training and awareness

Raise staff and volunteer awareness of environmental issues and promote individual good practice through briefings and the presence of Environmental Champions.


Require suppliers to provide goods and services with the minimum adverse environmental impact

Ensure that goods and materials purchased comply fully with UK government and EU legislation and recognised environmental best practice

Utilities and natural resources

Make efficient and environmentally responsible use of energy, water, and other natural resources


Minimise waste by ensuring all operations are as efficient as possible

Actively promote re-use and recycling, both internally and with suppliers


The use of cars for single occupant journeys is discouraged; staff will be encouraged to use public transport, cycle, and walk to work

This will be supported through the provision of season ticket and bike loans to all staff

Air travel will be used only where there is no alternative viable option


We will aim to meet or exceed all the environmental legislation that relates to the UK


All staff and volunteers will be expected to take measures to minimise environment impact through simple measures

Managers and heads of department will ensure that environmental issues are integrated into the planning and decision-making process


Communicate environmental performance both within the organisation and to the external community through the Accountability Review

These commitments will be demonstrated through the introduction of suitable policies, practices, and programmes. Environmental performance will be reported in our annual Accountability Review.

Equality, diversity, and inclusion policy

ICOR Ltd is committed to encouraging equality, diversity and inclusion among our workforce, and eliminating unlawful discrimination.

The aim is for our workforce to be truly representative of all sections of society and our customers, and for each employee to feel respected and able to give their best.

The organisation - in providing goods and/or services and/or facilities - is also committed against unlawful discrimination of customers or the public.

The policy’s purpose is to:

  • provide equality, fairness and respect for all in our employment, whether temporary, part-time or full-time

  • not unlawfully discriminate because of the Equality Act 2010 protected characteristics of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality, and ethnic or national origin), religion or belief, sex and sexual orientation

  • oppose and avoid all forms of unlawful discrimination. This includes in pay and benefits, terms and conditions of employment, dealing with grievances and discipline, dismissal, redundancy, leave for parents, requests for flexible working, and selection for employment, promotion, training or other developmental opportunities

The organisation commits to:

  • Encourage equality, diversity and inclusion in the workplace as they are good practice and make business sense

  • Create a working environment free of bullying, harassment, victimisation and unlawful discrimination, promoting dignity and respect for all, and where individual differences and the contributions of all staff are recognised and valued.

    This commitment includes training managers and all other employees about their rights and responsibilities under the equality, diversity and inclusion policy. Responsibilities include staff conducting themselves to help the organisation provide equal opportunities in employment, and prevent bullying, harassment, victimisation and unlawful discrimination.

    All staff should understand they, as well as their employer, can be held liable for acts of bullying, harassment, victimisation and unlawful discrimination, in the course of their employment, against fellow employees, customers, suppliers and the public

  • Take seriously complaints of bullying, harassment, victimisation and unlawful discrimination by fellow employees, customers, suppliers, visitors, the public and any others in the course of the organisation’s work activities.

    Such acts will be dealt with as misconduct under the organisation’s grievance and/or disciplinary procedures, and appropriate action will be taken. Particularly serious complaints could amount to gross misconduct and lead to dismissal without notice.

    Further, sexual harassment may amount to both an employment rights matter and a criminal matter, such as in sexual assault allegations. In addition, harassment under the Protection from Harassment Act 1997 – which is not limited to circumstances where harassment relates to a protected characteristic – is a criminal offence.

  • Make opportunities for training, development and progress available to all staff, who will be helped and encouraged to develop their full potential, so their talents and resources can be fully utilised to maximise the efficiency of the organisation.

  • Decisions concerning staff being based on merit (apart from in any necessary and limited exemptions and exceptions allowed under the Equality Act).

  • Review employment practices and procedures when necessary to ensure fairness, and also update them and the policy to take account of changes in the law.

  • Monitor the make-up of the workforce regarding information such as age, sex, ethnic background, sexual orientation, religion or belief, and disability in encouraging equality, diversity and inclusion, and in meeting the aims and commitments set out in the equality, diversity and inclusion policy.

    Monitoring will also include assessing how the equality, diversity and inclusion policy, and any supporting action plan, are working in practice, reviewing them annually, and considering and taking action to address any issues.

Details of the organisation’s grievance and disciplinary policies and procedures can be found by contacting the Director Mr Stephane Deleuze. This includes with whom an employee should raise a grievance.

Use of the organisation’s grievance and/or disciplinary procedures does not affect an employee’s right to make a claim to an employment tribunal within three months of the alleged discrimination.



  1. ICOR Ltd fully accepts the obligations placed upon it by the various Acts of Parliament covering health and safety. The Company requires its Chief Executive to ensure that the following policy is implemented and to report annually on its effectiveness.



  1. This policy has been prepared and published under the requirements of Health & Safety at Work legislation. The purpose of the policy is to establish general standards for health and safety at work and to distribute responsibility for their achievement to all managers, supervisors, and other employees through the normal line management processes.






  1. Director has overall responsibility for the implementation of the Company's policy. He is responsible for ensuring that the policy is widely communicated and that its effectiveness is monitored.


Directors and Senior Managers


  1. These managers are wholly accountable to the Chief Executive for the implementation and monitoring of the policy within the area of their specified responsibility.


Safety Officer


  1. The Safety Officer is a nominated manager responsible for co-ordinating effective health and safety policies and controls across the organisation.


  1. The Safety Officer is responsible for:


  • the production and maintenance of the Company's policy and ensuring that Department Guidelines are consistent with policy;

  • its application;

  • monitoring and reporting on the effectiveness of the policy;

  • the provision of general advice about the implication of the law;

  • the identification of health and safety training needs. The safety officer also acts on behalf of the Chief Executive, as the Company's formal link with the Health and Safety Executive, Environment Health Departments and other external agencies;

  • the production and maintenance of any health and safety documents or codes of practice as necessary for any relevant area of the Company services where this is required.







Stephane Deleuze

All ICOR Ltd Department Managers are accountable to the Director for their respective areas




  1. ICOR Ltd believes that consideration of the health, safety and welfare of staff is an integral part of the management process. The provision of the Health and Safety at Work etc Act, associated Codes of Practice and other relevant Directives will be adopted as required standards within the Company. Responsibility for health and safety matters shall be explicitly stated in management job descriptions.


  1. The Company requires managers to approach health and safety in a systematic way, by identifying hazards and problems, planning improvements, taking executive action and monitoring results so that the majority of health and safety needs will be met from locally held budgets as part of day-to-day management, although many health and safety problems can be rectified at little additional cost.


  1. For major additional expenditure, cases of need will be submitted by Directors to the Chief Executive.


  1. If unpredictable health and safety issues arise during the year, the Chief Executive must assess the degree of risk, in deciding the necessary resources and actions to commit to addressing these issues.




  1. It is the policy of ICOR Ltd to require departmental managers to produce appropriate departmental health and safety policies or guidelines. These should embody the minimum standards for health and safety for the department and the work organised within it.


  1. It shall be the responsibility of the manager to bring to the attention of all members of his or her staff, the provisions of the guidelines, and to consult with appropriate Health and Safety Representatives about the updating of these guidelines. Suggested model contents of a guideline are:


  • a clear statement of the role of the department;

  • regulations governing the work of the department;

  • clear reference to safe methods of working, for example nursing procedures, manufacturers' manuals;

  • information about immediate matters of health and safety concern, such as fire drills, fire exits, first aid;

  • training standards;

  • the role and identity of the Health and Safety Representative;

  • names of specialist advisers who can be approached about the work of the department;

  • the manager responsible for organisation and control of work;

  • accident reporting procedures;

  • departmental safety rules;

  • fire procedures;

  • policies agreed by the Company.





  1. It is the policy of ICOR Ltd to require a thorough examination of health and safety performance against established standards in each department, at least annually. The technique to be adopted for such examinations will be the 'Safety Audit'. The Audit requires review of:


  • standards laid down in the policy;

  • departmental guidelines;

  • relevant regulations;

  • environmental factors;

  • staff attitudes;

  • staff instructions;

  • methods of work;

  • contingency plans;

  • recording and provision of information about accidents and hazards and the assessment of risk.


  1. The information obtained by the Audit will be used to form the basis of the plan for the department for the following year.


  1. The responsibility for ensuring that audit activity is carried out as part of this policy rests with the Chief Executive and will be carried out by the Safety Officer. Although the Audit remains a management responsibility, managers are required as part of this policy to seek the involvement of the appropriate Health and Safety Representative in the conduct of the Audit.


  1. It is the management's responsibility to ensure that any deficiencies highlighted in the Audit are dealt with as speedily as possible.


  1. In addition to carrying out Safety Audits, it is the responsibility of the department manager to have checked, at least quarterly, all portable equipment, including electrical appliances, in their area, and to ensure that all problems are immediately dealt with.


  1. Managers have a continual responsibility for the elimination of hazards in order to maintain a safe working environment and will also be expected to carry out regular risk assessments in line with the Health and Safety Executive Guidelines; that is follow the 5 steps:


  1. Identify the hazards

  2. Decide who might be harmed and how

  3. Evaluate the Risks and decide on precautions

  4. Record the findings and implement the precautions

  5. Review the assessment and update when necessary




  1. ICOR Ltd will support Safety Representatives in carrying out their role and give all reasonable assistance. Safety Representatives will be encouraged to discuss specific health and safety issues with the relevant Head of Department. They may also formally report hazardous or unsafe circumstances to the Head of Department and will be formally notified of the remedial action taken or be given a reason why the action cannot be taken.




  1. Health and Safety training shall be incorporated within annual training programmes, as part of the development of a systematic training plan. Health and Safety training needs will, therefore, be identified and planned for in the same manner as other training needs.


  1. Four areas of need shall be given special priority:


  • training for managers, to equip them with an understanding of the manager's responsibilities under this policy, and the role and purpose of safety representatives;

  • training for safety representatives to enable them to discharge their function;

  • training for all members of staff to acquaint them with the main provisions of the law and its practical implication, the main features of this policy and key safety rules;

  • induction and in-service training for staff at all levels to acquaint them fully with new requirements and hazards.




  1. The Company will operate systems for recording, analysis and presentation of information about accidents, hazard situations and untoward occurrences. Advice on systems will be provided by the Safety Officer, in conjunction, where appropriate with specialist advisory bodies for example local Environmental Health Departments, and the responsibility for the operation of these systems rests with managers and supervisors at all levels. Information obtained from the analysis of accident statistics must be acted upon and, where necessary, bids for additional expenditure made to the Chief Executive.




  1. The responsibility for meeting the requirements of the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1985 (RIDDOR) to the Health and Safety Executive, shall rest with the Chief Executive as delegated to the Safety Officer.




  1. Certain bodies and the individual members of those bodies, have always had a Health and Safety role, most notably, the Health & Safety executive, or local Environmental Health Departments. If further specialist advice is required, this may be obtained by Managers from expert individuals or bodies outside the Company.




  1. It is the policy of the Company to obtain independent Occupational Health advice when required. Such services can include counselling on health and associated matters, investigation of hazards and accidents, environment studies, health interviews and employment medicals.




  1. It is the policy of the Company to make provision for First Aid and the training of 'First Aiders' in accordance with the First Aid Regulations (1982). The Safety Officer is responsible for ensuring the Regulations are implemented and for identifying training needs.




  1. The Chief Executive is responsible for ensuring that the staff receive adequate fire training, and that nominated fire officers are designated in all ICOR Ltd premises. The Chief Executive delegates these responsibilities to the Directors.


  1. In addition, the Company will nominate a Fire Officer (this may be the Safety Officer or someone external to the Company) who will:


  • report and advise on the standard of fire safety in the Company's premises and the standard of fire training of its staff;

  • undertake overall responsibility for fire training;

  • assist in the investigation of all fires in the Company's premises and to submit reports of such incidents.




  1. Procedures for the, condemnation and disposal of equipment are determined by the Chief Executive. Managers introducing new equipment should have such equipment checked initially by the Safety Officer.




  1. Those Managers who have responsibility for food acquisition, storage, processing and serving, and staff induction and hygiene training, are responsible for ensuring that these functions are undertaken to the necessary legal standards. Any suspected outbreak of food poisoning or other unexplained and possibly food related incidents must be reported to the Safety Officer.




  1. Managers are responsible for informing staff of safe lifting techniques. The Safety Officer will identify specific training needs and ensure training in lifting and handling is provided to staff who require it.




  1. ICOR Ltd policy is that there will be no smoking in its buildings. The overall aim is to reduce smoking and so save life, reduce risk of fire, prevent unnecessary illness and chronic disability. The rules relating to smoking on Company premises are available from Head Office. These rules also extend to e-cigarettes / vaping.




  1. The Control of Substances Hazardous to Health Regulations (COSHH) require the Company to identify those substances which are in use and which are hazardous to health (as legally defined) and to assess the risk of those substances. The Company must also provide and use controls to prevent exposure to substances hazardous to health; maintain controls by monitoring exposure, or by health surveillance of employees; and provide information, instruction and training for employees on all these matters. The Safety Officer is responsible for implementing these Regulations.




  1. All new computer installations must adhere to the British Standard Specifications and comply with the Health and Safety (Display Screen Equipment) Regulations 1992. All new employees operating such equipment are expected to read the Health and Safety Executive guidance entitled 'Working with Display Screen Equipment'. New employees who regularly use VDUs will be required to undergo sight screening.




  1. ICOR Ltd is committed to the principles of the Working Time Regulations. No member of staff is expected to work more than 48 hours per week (including overtime) unless there are exceptional circumstances. Similarly, all other requirements of the regulations e.g. in relation to breaks, night workers etc. will be complied with.




  1. The Health and Safety at Work Act requires each employee 'to take reasonable care for the Health and Safety of himself and of other persons who may be affected by their acts and omissions' and co-operate with management to enable management to carry out their responsibilities under the Act. Employees have equal responsibility with the Company for Health and Safety at Work.


  1. The refusal of any employee to meet their obligations will be regarded as a matter to be dealt with under the Disciplinary Procedure. In normal circumstances counselling of the employee should be sufficient. With a continuing problem, or where an employee leaves themself or other employees open to risk or injury, it may be necessary to implement the formal stages of the Disciplinary Procedure.




  1. Persons working in ICOR Ltd premises who are employed by other organisations are expected to follow Company Health and Safety Policies with regard to the safety of Company employees, their own personal safety (and that of other parties such as the general public if appropriate) and their method of work. This responsibility will be included in contracts or working arrangements.




  1. The Company wishes to ensure that as far as is reasonably practicable, the Health, Safety and Welfare of visitors to Company establishments will be of the highest standard.


  1. Any member of staff who notices persons acting in a way which would endanger other staff, should normally inform their Head of Department. If the danger is immediate, common sense must be used to give warning, call for assistance or give aid as necessary. It is equally important not to over-react to a situation.




  1. The Company wishes to ensure that as far as is reasonably practicable, the Health, Safety and Welfare of Contractors working in the Company's establishments will be of the highest standards. In addition, Contractors and their employees have an obligation so far as is reasonably practicable to ensure all equipment, materials and premises under their control are safe and without risks to health.


  1. Contractors must also observe the Company's Fire Safety Procedures. These obligations will be drawn to the attention of the Contractors in the contract document issued to them. In addition, a Company Manager will be identified in the contract as having authority to stop the work of Contractors who are placing themselves, other staff, or visitors at risk. Any member of staff who judges there is a risk where contractors are working, should inform their Manager immediately.


  1. In tendering, Contractors will be asked to confirm they have a written Health, Safety and Welfare Policy. The Company's Manager letting the Contract will be responsible for monitoring the Health and Safety performance of the Contractor and the Contractor's performance will be a factor in deciding whether to invite the Contractor to tender again.



We are committed to improving our practices to combat slavery and human trafficking. We

recognise that slavery and human trafficking is a real yet hidden issue in our society. We will not

tolerate slavery and human trafficking in our business or supply chain. 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 that any form of slavery is not taking place in our

own business or supply chains.


Organisation's structure

We are a service-led supplier to the glass replacement trade. Our ultimate parent company is

ICOR SA with our head office based in Belgium.


Our business

We operate a number of internal policies to ensure that we are conducting business in an ethical

and transparent manner. These include:

  1. Recruitment – we operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.

  2. Whistleblowing – our whistleblowing policy ensures that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisal.

  3. Health and Safety – this policy sets out our approach to ensure we provide a healthy working environment for our staff and contractors that work out of our premises.


Further steps


We intend to take the following further steps to combat slavery and human trafficking:

Risk assess all new suppliers using the Global Slavery Index and ask them to certify that they have

  1. taken steps to eradicate modern slavery within their own organisation and supply chain.

  2. notify all existing suppliers of our expectations and their obligations in relation to the prohibition of modern slavery.

  3. incorporate anti-slavery and human trafficking obligations into procurement agreements

  4. subcontracting arrangements on a risk assessed basis.

  5. include appropriate measures in our due diligence processes for sourcing suppliers,

  6. subcontractors and acquisitions on a risk assessed basis.

  7. provide training to relevant Group employees to ensure a high-level understanding of the risks of modern slavery and human trafficking; and

  8. where appropriate we will include reference to the Modern Slavery Act 2015 in our policies and procedures.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes

our Companies slavery and human trafficking statement for the current financial year.

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