Our Terms and Policies

Part 1: Policy details

What does this policy cover, and who is covered?

This Policy applies to all employees (including officers of the Eligo Group of Companies), contractors, consultants, candidates (already placed or awaiting placement), interns, and casual and agency workers who are covered by the terms of this policy.

We set out in this policy document what a person to whom it applies should do if s/he has reason to believe that something dangerous, unlawful or unethical is going on at work and it is affecting (or risks affecting) him/her, fellow colleagues or any third party.

Any person reporting a concern of this kind is known as a “whistleblower” and the action s/he takes is called whistleblowing.

The Eligo Group of Companies is committed to operating at all times, and in everything that we do, to the highest standards of probity and integrity.

Unfortunately, all organisations can occasionally be affected by conduct on the part of one or more persons that is dangerous, against the law or breaches ethical or professional codes.

If you become aware of any behaviour which you are suspicious about, please follow the procedure outlined at Part II of this policy to immediately report any concerns that you have about such action or conduct, so that we can take the necessary action to address these concerns as fast as possible.

This policy also covers the actions of third parties such as suppliers, service providers, and clients, as well as our employees, contractors, candidates etc. If you are concerned about a third party, please also raise them with us before approaching anyone else. Aleks Dimitrova, our Operations and Finance Manager will be able to explain how you should proceed.

We will always take your concerns seriously and they will be thoroughly investigated by a senior member of our Management Team. Most importantly, you should feel confident to follow the Part II procedure with confidence. There will be no reprisals for individuals who bring these concerns to our attention – we value and respect all such reports and those who make them to us. We all play an important role in ensuring that our business and everyone working in and with it acts professionally, lawfully, and appropriately.

It is not part of your employment contract

This policy is not part of your employment contract. The Eligo Group of Companies may amend this policy at any time. Nothing in your Contract of Employment takes precedence over the policy as the right to act as a Whistleblower is a statutory right, not limited by any contractual obligation to us as your employer, if you are an employee.

What sorts of activities are typically considered relevant to whistleblowing?

This is not an exhaustive list, but the types of concerns you may want to raise with us by whistleblowing could include:

• Any activity you suspect may constitute a criminal offence
• Any activity you suspect may put you or any third party at risk due to a breach of health and safety legislation
• Any activity you suspect may result in damage to the environment
• Any activity you suspect breaches any of our other Eligo Group policies e.g. on bribery and/or corruption
• Any failure which you believe results in non-compliance with legal or regulatory obligations
• Any failure which you believe results in a failure of one or more persons to meet professional requirements
• Any attempt you become aware of by any person to conceal one or more of these activities

Please speak to Aleks Dimitrova, our Operations and Finance Manager if you are unsure whether something that you are concerned about is covered by this policy.

Bullying or harassment

If your complaint is about the behaviour of others towards you, our Bullying and Harassment Policy or the Grievance procedure contained in our Employee Handbook contain the relevant guidance on how to proceed. These types of behaviour are not covered by this whistleblowing policy but may justify Disciplinary action being taken against a person responsible for such behaviour.

Confidentiality and anonymity

You are always encouraged to raise concerns openly with the designated manager Aleks Dimitrova, our Operations and Finance Manager. If for any reason you feel unable to discuss any matter with her, you should raise it with Andrew Molloy, our Managing Director. We actively discourage anonymous whistleblowing because it is not always easy to manage and investigate anonymous reports. It can be difficult to separate genuine concerns from e.g. “idle gossip or rumour”, especially if we are unable to ask you for clarification or further details. This may result in us struggling to clarify any point and find evidence to support your allegations and/or reach an informed conclusion. In these circumstances, we risk missing evidence or opportunities to gather important supporting information, or identify helpful witnesses, because we may simply be unaware of their existence, in spite of our best efforts to uncover them.

However, if you prefer to keep your identity anonymous, we will do all that we can to ensure that you retain your anonymity, and the confidentiality of your concerns, as far as possible. If we need to disclose your identity to others as part of the investigation, we will always discuss with you beforehand both our desire and our reasons for wishing to identify you.

We will protect you from reprisals, and you can read more about how we do this and what rights you have in section 5 below.

We protect whistleblowers

There are no reprisals for mistakes or if following our investigations, (which we will always conduct thoroughly and conscientiously), we conclude that there has been no breach of law, policy or unethical conduct. However, to qualify for protection, the disclosure must, in the reasonable belief of the worker making the disclosure, show that one or more of the following events has happened, is happening or is likely to happen and that it is in the public interest to make the disclosure:

• A criminal offence
• Failure to comply with any legal obligation
• Miscarriage of justice
• Danger to health & safety of any individual
• Danger to the environment, or,
• Deliberate concealment of any of any of the above.

If at any time, you do not feel that you have been fairly or properly treated by us in the handling of your whistleblowing concern, you must inform us immediately. You should inform Victoria Bodhani, our General Manager in the first instance; and if you are not satisfied with the outcome of that conversation, you should follow the process set out in our grievance policy.

We also protect whistleblowers from others, so where a whistle-blower reports to us that they have been treated inappropriately by others, (including having received threats as a result of raising their concerns), we will take disciplinary action against those individuals in accordance with the procedure set out in our Employee Handbook. The consequences of us taking this action could include dismissal of such individual(s) for gross misconduct. Whistleblowers may also be entitled to take legal action against those individuals.

If you would like more information about your rights as a whistle-blower and how you are entitled to be protected, you can contact Public Concern at Work, which is an independent charity offering a confidential helpline on 020 7404 6609; www.pcaw.org.uk.

Whistleblowing to others outside of The Eligo Group of Companies

Our policy covers the process for raising, investigating, and resolving wrongdoing within the workplace of any company within the Eligo Group of Companies.

The whistleblowing procedure that we have carefully put in place has been designed to ensure that to the best of our ability, we are able to resolve any concerns raised and to protect you as part of this process.

For these reasons, we anticipate that it would be extremely rare, if ever necessary, for you needing to involve anyone outside of the Eligo Group of Companies as part of this process.

However, we recognise that potentially, in exceptional circumstances, you might wish to involve an external body – an industry regulator, for example – and/or the independent charity Public Concern at Work, who can direct you towards the appropriate regulator for the type of issue you want to raise.

Involving the press/media

Involving the media in a whistleblowing matter often has the effect of inflaming the situation, not assisting it. It can significantly hamper evidence gathering and the willingness of other relevant individuals to support the process.

We therefore strongly discourage you from involving the media. We may treat any contact with the press as a serious disciplinary issue justifying dismissal unless exceptional circumstances exist. For example, we would generally expect you to have taken all reasonable steps to deal with the matter internally, or with an external regulator, and to have taken full advice from a solicitor or from Public Concern At Work, before you could justify involving the press.

Part II: Our procedure for raising a whistleblowing concern

Please follow this procedure:

• Raise your concerns with Aleks Dimitrova, our Operations and Finance Manager in the first instance. You may do so in writing or in person.
• If you would prefer not to discuss your concerns with Aleks Dimitrova, or you consider that your concerns are extremely serious, you should write to Victoria Bodhani, our General Manager.
• Please explain that you are raising your concerns as part of the Eligo Group of Companies Whistleblowing Policy and procedure. Then set out all the key facts, including names of those involved and all relevant dates.
• You will be invited to a meeting at which you can discuss your concerns. You are entitled to bring someone with you to this meeting – and any subsequent meetings. That companion may be a colleague (or a trade union representative, if relevant). Anyone who accompanies you will be asked to agree to keep strictly confidential the contents of the meeting including any materials disclosed and/or examined during it. This obligation of confidentiality will extend before, during and after the meeting and any subsequent or follow-up investigation that we conduct in relation to the concerns raised by you.
• Following this meeting, we will investigate the matters raised and we may request that you come to additional meetings to assist us in our efforts. We may also decide to involve Mark Sutherland-Fisher, our Group Company Secretary or relevant external specialists to help us conduct a thorough, fair and responsible investigation.
• Our relevant personnel involved in this investigation will keep you informed about the progress of the investigation as far as they are able. For a number of reasons, generally relating to legal obligations, including obligations of confidence, to others, or in relation to any legal advice that we may decide to take on our own behalf, we may not be able to share every detail of our discoveries or deliberations with you. We will always endeavour, however, to reassure you, as best as we can, of the fact that we are taking your concerns seriously and that we are conducting a responsible investigation.
• It is possible that the outcome of our investigations will not be one that you find satisfactory. If this happens, you are entitled to complain to Mark Sutherland-Fisher, our Group Company Secretary, and request a review of what has been done and concluded.

If you have raised a concern in good faith, our process and all those involved in giving effect to it will support and protect you. However, if a false concern is raised with us in bad faith (e.g. for malicious reasons), we may invoke our disciplinary policy and you may be subject to disciplinary action in accordance with the procedure set out in our Employee Handbook.

Structure, business and supply chain

The Eligo Group of Companies is a modern, dynamic group operating in the contract and permanent recruitment sectors, incorporating the Eligo Recruitment, Eligo Security and Eligo Medical brands. 

We are serious about our brand because it’s part of our identity and so is our commitment to corporate social responsibility. We believe transparency is the best way we can ensure the public that we are doing our best as an ethical corporate citizen. In that spirit although we are currently exempt from the requirements of the legislation, we have published our annual statement for slavery and human trafficking, made in compliance with section 54 of the Modern Slavery Act 2015, in which we explain how slavery and human trafficking can affect our business and the steps we are taking in the fight against it. This slavery and human trafficking statement addresses the steps taken by each of our Group of Companies, namely Eligo Medical Ltd, Eligo Recruitment Ltd, Eligo Security Ltd and Eligo Towers Ltd . This statement is intended to fulfil the legal requirement for a slavery and human trafficking statement on behalf of all companies within the Eligo Group, as relevant. Our efforts against slavery and human trafficking complement our broader CSR Policy and our adoption of the Ethical Trading Initiative.

All Eligo Group Companies are headquartered in London, England. We provide recruitment services throughout Europe, including the United Kingdom. We do not produce, sell or supply goods of any sort. We provide recruitment services by sourcing candidates from across the world that we believe have the academic skills and professional experience to meet the needs of our clients. These candidates may either be placed by us becoming employees of our clients or in short-term temporary/longer-term contractor roles becoming either our employees or operating as self-employed contractors (“workers”) providing services to our clients via our companies. We have around 35 employees within our Group in addition to approximately 100 workers who are engaged through our supply chain. We source candidates in one of two ways. Either they respond to adverts we place on well-known industry “job boards” seeking candidates with specific job skills and experience or we contact candidates who have become known to us either through established business networking groups or who have achieved some form of recognition or publicity due to their skills and expertise.

Building on our existing CSR Policy and our commitment to the Ethical Trading Initiative, we have embraced the requirement to publish an annual slavery and human trafficking statement. This will allow us to share our efforts against slavery and human trafficking and improve and measure our success each financial year. This past financial year ending 31 March 2019, we took the following key steps to ensure slavery and human trafficking did not occur within our organisation or supply chain.

Slavery and human trafficking policies

Notably, we have begun to develop a Slavery and Human Trafficking Policy, which on completion will be found within our new Corporate Social Responsibility (CSR) Policy. We have also begun to develop a Supplier Code of Conduct. It will set out clear objectives for 1, 3 and 5 year slavery and human trafficking plans around the following themes:

• Relationships: Strengthening our supplier engagement process

• Feedback: Establishing grievance mechanisms and channels for individual worker feedback

• Knowledge: Improving our knowledge base by collecting relevant data and improving Candidate sourcing techniques

• Third party engagement: Building strategic alliances with independent organisations and other businesses/bodies within the recruitment industry 

• Measurable change: Developing verifiable KPIs to measure progress

• Supplier collaboration: Encouraging workers to collaborate to address slavery and human trafficking issues

• Accountability: Establishing a framework for organisation accountability to allow for raising issues, making suggestions, voicing grievances and reporting slavery and human trafficking

Due diligence procedures

We understand that our biggest exposure to Modern Slavery is in our sourcing candidates and workers from out with the United Kingdom, where we have undertaken activity over the last decade to minimise the risk of Modern Slavery. Within these areas, new suppliers and candidates/workers are subject to due diligence checks in the form of ethical/compliance audits. Such audits are also regularly conducted for existing suppliers and candidates/workers, including those operating within the United Kingdom. These audits assess compliance with the Global Sourcing Principles and are, amongst other things, intended to identify any Modern Slavery practices. If issues are identified, appropriate investigative and remedial actions will be taken.

Identifying, assessing, and managing risk

We set out to identify the extent of any slavery and human trafficking in our supply chains by:

• Conducting a thorough check of all academic, professional and national identity documentation, including any bank account or financial details obtained

• Engaging with all new candidates and workers to assess whether they are being “manipulated” by any unknown third party

• Interviewing (usually via digital communication) candidates and workers to discuss their existing conditions and their right to live and work in the location where clients wish to place them

• Constantly updating and evolving our work practices to develop an improvement plan to address new and previously identified slavery and human trafficking issues

• Instituting an annual review questionnaire (from April 2020)for existing candidates and workers to understand their self-assessment of slavery and human trafficking issues, allowing us to better identify slavery and human trafficking issues as they develop over time and to collect candidate and worker-provided data to track improvement in their attitudes.

We have not thus far discovered any slavery and human trafficking in any part of our supply chain. However we recognize that as less dependence is made on candidates and workers coming from other parts of the European Union and more become accessible from India, China and other parts of the non-European world, there will be a greater exposure to opportunistic trafficking occurring. 

Key performance indicators

In order to assess the effectiveness of our modern slavery measures we will be reviewing the following key performance indicators:

• Staff training levels

• Number of slavery incidents reported in the supply chain

 Training available to staff

A key part of our slavery and human trafficking strategy is to promote cultural change through training. We have not thus far offered training but in the 2019-2020 financial year we will:

• Offer online training modules on modern slavery to all staff

• Ensure all staff are aware of current United Kingdom Home Office guidance and advice

• Run internally or send staff on such training seminars as may seem appropriate 

• Aim to start development of a dedicated training and resources webpage which individual candidates and workers in the supply chain will be able to access to learn about modern slavery and human trafficking, understand their rights and anonymously report any slavery and human trafficking issues in their workplace.

About this statement

This statement was prepared by Cadboll Business Consultancy applying a template provided by VinciWorks, a leading provider of compliance training to over 80,000 people around the world. VinciWorks released a free guide to compliance with the Modern slavery Act and a new online modern slavery course. To learn more please visit www.vinciworks.com/modernslavery.

Within the Eligo Group of Companies (Eligo Recruitment Limited, Eligo Security Limited and Eligo Medical Limited) protecting your privacy is very important to us. 

Our Privacy Policy sets out the basis on which we process any personal data that we collect from you or about you that you provide to us or that we receive from other sources. It also sets out how we expect you to assist us in protecting third party data we require to collect such as that provided by our suppliers and customers. We’re committed to protecting the privacy of our employees, candidates, suppliers, contractors, customers, and users of our website, I.T., and telephonic systems, and provide a safe and secure user experience. 

The Eligo Group of Companies will always treat your personal information with the utmost respect and act in accordance with this Privacy Policy and legislation as set out in The Data Protection Act 2018 (DPA) and the General Data Protection Regulation 2016 (GDPR) in so far as it may still apply in England or other parts of the United Kingdom.

Our Privacy Promise

We promise that we’ll tell you how we use your data and we’ll use it to provide the best service possible for you. Plus, we’ll make sure we collect and store your data securely. 

The way we process and use your personal data will always conform to the way we work throughout our organisation, linking to our values and continued emphasis on our services being all about you.

Doing the right thing

You are our number one priority. We have to collect and keep a little data about you, like your name and home/business address, email address, and other items listed later in this policy document. We also have to share your data with our trusted partners, such as our accountants or 3^rd party who process our P.A.Y.E. system and H.M.R.C. and occasionally with customers to successfully do our job as a painting and decorating company. We also have to share your data with our trusted partners, such as our lovely clients or candidates to successfully do our job as a recruitment agency.  

We promise to collect, process, store, and share your data safely and securely. We’ll also make sure that the other businesses we work with are just as careful with your data.

We’ve got your back

Ultimately, we use your data to ensure you are paid the correct amount (employees and contractors), get you a job (candidates), invoiced for the correct amount (customers), paid the correct amount to the correct bank account (suppliers) or for the reasons you’ve provided consent to store and use your data (marketing communication, useful information, etc.). We’ll use the details you share with us to let you know about employment opportunities suited to you, keep you updated whilst working with us, or for other things that might be relevant to your employment or to your job hunt. Should you not arrive for work and we are unable to contact you, we may also use your information to get in touch with your nominated emergency contact to find out if you are unwell or otherwise ascertain you are safe. For our suppliers and customers, we may use the information you have provided to advise you of changes to our working hours or schedules for delivering work, ordering or delivery requirements, or sending you reminders in relation to actual or proposed works to be carried out on your behalf. Plus by listening to what our candidates and clients tell us, we can make changes, secure you the best opportunities, and make things better where we can.

Going beyond expectation

We make sure our recruitment service is all about you. This means that throughout working with us we’ll be able to provide a service tailored directly to your needs. If you choose to receive email marketing from the Eligo Group of Companies, we can let you know about new opportunities or services, provide you with useful content and updates from us and continue to go beyond the remit of what you expect from your recruitment agency.

Remember that whatever consent you give, you’re in control and are able to manage these preferences at any time.

Be more you 

You’re always in control of your data and are welcome to amend your preferences at any time.

If you would like to stop receiving marketing from us, you are able to review and amend your preferences at any time by (volcanic or RDB) or emailing us at dataprotection@eligo.co.uk. If the information we hold on you is wrong, you can email us at dataprotection@eligo.co.uk , let us know what needs updating and we will correct it.

When it comes to your data, with the Eligo Group, it really is all about you.

The Legal Stuff – Our Privacy Policy in full

Who are we?

The Eligo Group of Companies are recruitment and employment agencies operating within specialist markets, comprising three companies; Eligo Recruitment Ltd. (04154618), Eligo Medical Ltd. (07920513) and Eligo Security Ltd. (07920420) all incorporated under the Companies Acts in England and Wales and having their Registered Office and Principal Place of Business at Suites 1 & 3 Hatton House, 83 Hartfield Road, London, England, SW19 3ES. 

The information and policies set out in our privacy policy apply to all interactions with these companies. In regards to our Privacy Policy and compliance with data protection regulations, the data controller for our set of companies is Eligo Recruitment Ltd.

Our Privacy Policy

This Privacy Policy explains how personal information, about you, may be collected, used, or disclosed as a consequence of your interactions with us and/or your activities on the Eligo website. 

Please read this policy carefully to understand our practices regarding your personal data. We recommend that, from time to time, you visit our website to review this policy and stay up to date with any changes to it.

If would like to read more about how Eligo Recruitment Ltd processes your personal data, you can more information in our GDPR and Personal Data FAQ here.

This privacy policy covers:

• Data Protection Obligations
• The information we collect and how we use it
• How do we collect your data
• Use of information by Eligo
• Access and accuracy and update of personal information
• Cookies 
• Contact us

What establishes our data protection obligations to you?

Eligo Recruitment Ltd. is required to process your personal data in accordance with the law.

The Data Protection Act 2018 (DPA) implements the EU Data Protection Directive 1995 (EU Directive 95/46/EC).

On 25 May 2018 when the General Data Protection Regulation 2016 (EU Regulation 2016/679) came into force; the DPA also came into force in anticipation of the United Kingdom leaving the European Union and E.U. law ceasing to apply within the United Kingdom on 31^st December 2019.

This privacy policy complies with the DPA and GDPR.

What information may we collect from you?

Eligo limits the collection of your personal information to that which is required or permitted by law. Eligo collects such personal information as is required for the purposes identified in this Privacy Policy or identified by Eligo at the time that we collect the information from you. 

This information will only ever be used for these relevant purposes and for reasons as consented to by you. For example, if you have consented to your personal data being stored in relation to your job search (candidates) or your employment (employees) and not marketing activity, this is the only purpose for which it shall be held.

Information that we may collect from you includes but is not limited to;

• Preferences to receive alerts regarding to job opportunities
• Name, Address, Date of Birth, National Insurance Number and personal bank account
• Email Address, Landline and/or Mobile telephone number
• Former Employment history and P45/P60, Proof of Nationality and/or Right to Work in the United Kingdom
• Name, address and emergency contact details for your next of kin or nominated person
• Data as required by law
• Anonymised data for usage in market reports, salary surveys and other collateral relevant to our industry
• Information on your visits to our website including but not limited to traffic data, location data, weblogs, and other communication data and the resources you access.
• Any information regarding contact with you that may be needed as record of correspondence
• Information for direct marketing via e-mail, messaging, or telephone. You may opt out of these at any time. 
• We also may store cookies as set out in our cookie policy detailed on our website

How does Eligo Recruitment Ltd. collect your data?

• Information that you give to us:
• Personal data is that which you provide to us, for example by filling in forms on our website, submitting your CV or applying to a job , (www.eligo.co.uk) or by corresponding with us by telephone, e-mail, post, and social media or otherwise.
• This personal data would relate to applications for a particular role, allowing us to match suitable assignments for you as long as you require us to. We will process your email address and mobile number to provide you with any alerts regarding future work opportunities and positions that we feel will suit your own requirements, as well as for reasoning such as payment advice relating to employment positions . 
• To find out more about the purposes for which we intend to use this personal data and how long we keep that data, please view our FAQs.

Information that we receive from other sources

This is the personal data that we receive about you from others. As a recruitment business, Eligo Recruitment Ltd. also works closely with third parties including, for example, Job boards, Payroll providers, and Reference services in order to provide and maintain your employment position. We also works closely with third parties including, for example, public organisations, N.H.S. Hospital Trusts and G.P. practices for whom we are supplying sub-contractor services or who are supplying sub-contractor services to us, and Reference services we may use to assess the credit worthiness of an existing or potential individual customer or supplier.

We also cooperate with and report to government agencies and regulatory bodies, such as the HMRC, BIS (Department for Business, Innovation and Skills), Department for Work and Pensions, the Pension Regulator, to ensure that we are meeting our statutory obligations and providing an acceptable level of service to you and all of our customers.

Any information collected from third party sources will be for purposes relevant to you and we ensure that all third parties that we work with are also DPA/GDPR compliant.

To find out more about the personal data that we collect from third parties, the purposes for which we intend to use this, and how long we keep that data, please view our FAQs.

Information we collect when visiting our website

In line with our information security standards, we monitor website behaviour through website analytics. We collect information about how each visitor uses our site. These are then used to compile reports and to help us improve our site. Information is collected in an anonymous form, including:

• the number of visitors to the site
• where visitors have come to the site from
• the pages visited

Eligo Recruitment Ltd. wants to provide you with the best possible service. We are always looking for ways to improve. This includes improving our website so that it provides the information that you need, on a regularly updated basis and in an easily accessible way.

How does Eligo Recruitment use your data?

All personal data will be collected and handled by Eligo Recruitment Ltd for the following purposes:

• To best tailor the job searches according to your preferences (candidates).

• To best tailor the information needed to enable you to carry out your work (employees).

• To keep you informed by email, telephone and/or mail about future work opportunities and marketing communication.

• To deliver other services – such as newsletters, events, or training – that we may offer you.

• To help us create, publish, and improve content most relevant to you.

• To ensure that content from our Website is presented in the most effective manner for you and for your device.

• To allow you to participate in interactive features of our service, when you choose to do so.

• To further develop and improve our Website, Portal and other systems to better serve you.

Accessing your data

In compliance with DPA and/or GDPR you have the right at any time to ask us for a copy of the information supplied by you as well as additional information such as interview feedback that we currently hold.

If you would like to request a copy of the information held please contact our data protection officer at dataprotection@eligo.co.uk or (via the candidate portal on our website). 

Where this request also involves the deletion of data we have on file there may be some instances in which we may not be required or able to do so, particularly where this information pertains to client or financial information that we have to keep for legal matters e.g. tax. 

Where we cannot provide or process a request we will always provide reasons for not doing so.

Cookies on the Eligo Recruitment Website (www.eligo.co.uk)

Like most websites, our website uses cookies to distinguish you from other users. These are small text files stored in your web browser, which can identify you (or your device) when visiting our website. This helps us to check on the effectiveness of your experience and devise ways to improve our website to improve its content, search functions, and make it more user friendly.

Information that we may collect from your visit includes your device’s Internet protocol (IP) address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), services you viewed or searched for, page response times, and length of visits to certain pages.

For more information on our use of cookies, view our cookie policy.

Contact us

Eligo will make information about its policies and practices relating to management of personal information readily available. Please direct any questions about our privacy policies and procedures, any requests for access to our records of your personal information and any other privacy related concerns or complaints using our contact form.

You can contact us by using this contact form, through our phone number 0208 944 4180, email at dataprotection@eligo.co.uk, or by post to: Eligo Recruitment Ltd., Suite 1 & Suite 3, Hatton House, 83 Hartfield Road, Wimbledon, SW19 3ES

We are committed to the promotion of equality of opportunity at all levels within our organisation. This includes creating 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. It is our policy to provide equality of employment (and in respect of candidates and job applicants) to all, irrespective of:

• gender, including gender reassignment
• marital or civil partnership status
• having or not having dependents
• religious belief or political opinion
• race (including colour, nationality, ethnic or national origins, being a member of the traveller community)
• disability
• sexual orientation
• age

We oppose all forms of unlawful and unfair discrimination both direct and indirect. All our employees and candidates will be treated fairly and will not be discriminated against on any of the above grounds. Decisions on selection for employment, (presentation for employment in respect of candidates), office, training or any other benefit including rates of pay, hours worked etc. will be made objectively, without unlawful discrimination, and based on aptitude and ability. We recognise that the provision of equal opportunities in all our activities benefits our organisation. Our equal opportunities policy helps employees and candidates develop their full potential and we aim to fully utilise the talents and resources of our employees to maximise the effectiveness of the organisation. We recognise our statutory duty under the Equality Act 2010, to implement an equal opportunities policy. This policy applies to applicants for employment within our organisation, to our interaction with suppliers and customers (including all their employees), to candidates and job applicants using our services to secure temporary or permanent placements and to members of the wider community.

We are committed to the principles and practice of Equality. 

We value the diversity of the local population. We want our services, facilities and resources to be accessible and useful to every citizen regardless of gender, age, ethnic origin, religious belief, disability, marital status, sexual orientation, or any other individual characteristic which may unfairly affect a person’s opportunities in life.

Equality commitments

We are committed to:

• promoting equality of opportunity for all persons
• promoting a good and harmonious learning environment in which all individuals are treated with respect and dignity and in which no form of intimidation or harassment is tolerated
• preventing occurrences of unlawful direct discrimination, indirect discrimination, harassment and victimisation
• fulfilling all our legal obligations under the equality legislation and associated codes of practice
• complying with our own equal opportunities policy and associated policies
• taking lawful affirmative or positive action, where appropriate
• breaches of our equal opportunities policy will be regarded as misconduct and could lead to termination of employment 

This policy is fully supported by our Management Team.

Implementation

The Management Team has specific responsibility for the effective implementation of this policy. We expect all employees to abide by the policy and help to create an equality based environment which is its objective.

In order to implement this policy we shall:

• Communicate the policy to employees by issuing an induction sheet to all existing, and new employees and to candidates and job applicants when they register with us
• Endeavour through appropriate training to ensure that it will not consciously, or unconsciously discriminate in the selection or recruitment of applicants for employment 
• Incorporate specific and appropriate duties in respect of implementing the equal opportunities policy into roles and responsibilities of the Management Team
• Incorporate equal opportunities notices into general communications (e.g. announcements, annual report at annual general meeting, notices and newsletters). This policy will be made available to all members at each annual general meeting 
• Ensure that adequate resources are made available to fulfil the objectives of the policy

Monitoring and review

We will establish appropriate information and monitoring systems to assist the effective implementation of our equal opportunities policy. The effectiveness of the equal opportunities policy will be reviewed regularly (at least annually) and action taken as necessary. 

Complaints

Employees or candidates who believe that they have suffered any form of discrimination, bullying, harassment or victimisation are entitled to raise the matter through the agreed grievance procedures (section 7 of our Employee Handbook). The initial complaint should be made with the employee’s Line Manager (or if the complaint is about the Line Manager) with Andrew P. Molloy our Managing Director. All complaints of discrimination will be dealt with seriously, promptly and confidentially.

Every effort will be made to ensure that employees who make complaints will not be victimised. Any complaint of victimisation will be dealt with seriously, promptly and confidentially. Victimisation will result in disciplinary action and may warrant dismissal.

Complaints from members of the public will be dealt with under the same procedures.

For further information contact the Equality and Human Rights Commission who can provide free and confidential advice and guidance on promoting equality of opportunity. 

Scotland: 0845 604 5510 Text phone: 0845 604 5520 

Email: scotlandhelpline@equalityhumanrights.com

England: 0808 800 0082 Text phone: 0808 800 0084

Website: http://www.equalityadvisoryservice.com/

Policy Statement:

The Eligo Group of Companies believes that everyone we come into contact with, regardless of age, gender identity, disability, sexual orientation or ethnic origin has the right to be protected from all forms of harm, abuse, neglect, and exploitation. We will not tolerate abuse and exploitation by staff or associated personnel.

This policy will address the following areas of safeguarding [as appropriate]: child safeguarding, adult safeguarding, and protection from sexual exploitation and abuse. These key areas of safeguarding may have different policies and procedures associated with them.

The Eligo Group of Companies commits to addressing safeguarding throughout its work, through the three pillars of prevention, reporting, and response.

The Eligo Group of Companies abides by its duty of care to safeguard and promote the welfare of adults at risk, children, and young people and is committed to safeguarding practice that reflects statutory responsibilities, and government guidance and complies with best practice requirements.

• We recognise the welfare of adults at risk, children and young people is paramount in all the work we do and in all the decisions we take
• All adults at risk, children and young people, regardless of age, disability, gender reassignment, race, religion or belief, sex, or sexual orientation have an equal right to protection from all types of harm or abuse
• Some adults at risk, children and young people are additionally vulnerable because of the impact of previous experiences, their level of dependency, communication needs or other issues
• Working in partnership with adults at risk, children and young people, their parents, carers and other agencies is essential in promoting their welfare.

Purpose:

The purpose of this policy is to protect people, particularly adults at risk, children and young people from any harm that may be caused due to their coming into contact with the Eligo Group of Companies. This includes harm arising from: 

• The conduct of staff, candidates placed by or personnel associated with the Eligo Group of Companies
• The design and implementation of The Eligo Group of Companies programmes and activities 

The policy lays out the commitments made by The Eligo Group of Companies, and informs staff, associated personnel, and candidates placed in situations where they are in contact with adults at risk, children and young people of their responsibilities in relation to safeguarding. 

This policy applies to anyone working on behalf of the Eligo Group of Companies, including senior managers and the board of directors, paid staff, volunteers, sessional workers, candidates, agency staff and students. Failure to comply with the policy and related procedures will be addressed without delay and may ultimately result in dismissal/exclusion from the organisation.

This policy does not cover: 

• Sexual harassment in the workplace – this is dealt with under the Eligo Group of Companies Bullying and Harassment Policy
• Safeguarding concerns in the wider community not perpetrated by Eligo Group of Companies employees or associated personnel

Definitions:

Adult at Risk:

• An adult who has needs for care and support (whether or not the authority is meeting any of those needs),
• is experiencing, or is at risk of, abuse or neglect, and
• as a result of those needs is unable to protect themselves against abuse or neglect or the risk of it.

Beneficiary of Assistance

Someone who directly receives goods or services from an employee, candidate or agent of the Eligo Group of Companies. Note that misuse of power can also apply to the wider community that we serve, and also can include exploitation by giving the perception of being in a position of power.

Child: The definition of a child in The Children Act 1989 is anyone who has not yet reached their 18th birthday, even if they are living independently, are a member of the armed forces or is in hospital. 

Child and Adult Abuse: Children and adults may be vulnerable to neglect and abuse or exploitation from within their family and from individuals they come across in their daily lives. There are 4 main categories of abuse, which are: sexual, physical, emotional abuse, and neglect. It is important to be aware of more specific types of abuse that fall within these categories, they are:

• Bullying and cyberbullying
• Child sexual exploitation
• Child Criminal exploitation
• Child trafficking
• Domestic abuse
• Female genital mutilation
• Grooming
• Historical abuse
• Online abuse

Harm: Psychological, physical and any other infringement of an individual’s rights 

Psychological harm: Emotional or psychological abuse, including (but not limited to) humiliating and degrading treatment such as bad name calling, constant criticism, belittling, persistent shaming, solitary confinement and isolation

Protection from Sexual Exploitation and Abuse (PSEA): The term used by the humanitarian and development community to refer to the prevention of sexual exploitation and abuse of affected populations by staff or associated personnel. The term derives from the United Nations Secretary General’s Bulletin on Special Measures for Protection from Sexual Exploitation and Abuse (ST/SGB/2003/13)

Safeguarding: In the UK, safeguarding means taking all reasonable steps to prevent harm, particularly sexual exploitation, abuse and harassment from occurring; to protect people, especially vulnerable adults and children, from that harm; and to respond appropriately when harm does occur. In our sector, we understand it to mean protecting people, including children and at risk adults, from harm that arises from coming into contact with our staff, candidates or agents.  

This definition draws from our values and principles and shapes our culture. It pays specific attention to preventing and responding to harm from any potential, actual or attempted abuse of power, trust, or vulnerability, especially for sexual purposes.

Safeguarding applies consistently and without exception across our business, directors, candidates, agents and staff. It requires proactively identifying, preventing and guarding against all risks of harm, exploitation and abuse and having mature, accountable and transparent systems for response, reporting and learning when risks materialise. Those systems must be survivor-centred and also protect those accused until proven guilty.

Safeguarding puts beneficiaries and affected persons at the centre of all we do. 

Safeguarding children: Safeguarding children is defined in Working Together to Safeguard Children 2018 as: 

• protecting children from maltreatment. 
• preventing impairment of children’s health or development.
• ensuring that children are growing up in circumstances consistent with the provision of safe and effective care.
• taking action to enable all children to have the best outcomes.

Sexual abuse: The term ‘sexual abuse’ means the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. 

Sexual exploitation: The term ‘sexual exploitation’ means any actual or attempted abuse of a position of vulnerability, differential power, or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another. This definition includes human trafficking and modern slavery.

Survivor: The person who has been abused or exploited. The term ‘survivor’ is often used in preference to ‘victim’ as it implies strength, resilience and the capacity to survive, however, it is the individual’s choice how they wish to identify themselves.

Legal Framework:

This policy has been drawn up on the basis of legislation, policy and guidance that seeks to protect children in England. A summary of the key legislation is available from nspcc.org.uk/learning.

The Eligo Group of Companies should have in place arrangements that reflect the importance of safeguarding and promoting the welfare of children and young people as well as vulnerable adults.

Prevention:

The Eligo Group of Companies responsibilities

We will:

• Ensure all staff have access to, are familiar with, and know their responsibilities within this policy
• Design and undertake all our programmes and activities in a way that protects people from any risk of harm that may arise from their coming into contact with us. This includes the way in which information about individuals is gathered and communicated
• Implement stringent safeguarding procedures when recruiting, managing and deploying staff and associated personnel 
• Ensure staff receive training on safeguarding at a level commensurate with their role in the organisation
• Follow up on reports of safeguarding concerns promptly and according to due process

Staff responsibilities

Child safeguarding

Our staff and associated personnel must not:

• Engage in sexual activity with anyone under the age of 18 
• Sexually abuse or exploit children 
• Subject a child to physical, emotional or psychological abuse, or neglect 
• Engage in any commercially exploitative activities with children including child labour or trafficking 

Adult safeguarding

Our staff and associated personnel must not:

• Sexually abuse or exploit at risk adults
• Subject an at risk adult to physical, emotional or psychological abuse, or neglect 

Protection from sexual exploitation and abuse

Our staff and associated personnel must not:

• Exchange money, employment, goods or services for sexual activity. This includes any exchange of assistance that is due to beneficiaries of assistance
• Engage in any sexual relationships with beneficiaries of assistance, since they are based on inherently unequal power dynamics

Additionally, our staff and associated personnel are obliged to:

• Contribute to creating and maintaining an environment that prevents safeguarding violations and promotes the implementation of the Safeguarding Policy
• Report any concerns or suspicions regarding safeguarding violations by an Eligo Group staff member or associated personnel to the appropriate staff member 

The Prevent duty

Some organisations in England, Scotland and Wales have a duty, as a specified authority under section 26 of the Counterterrorism and Security Act 2015, to identify vulnerable children and young people and prevent them from being drawn into terrorism. This is known as the Prevent duty. These organisations include:

• Schools 
• Registered childcare providers
• Local authorities
• Police
• Prisons and probation services
• NHS trusts and foundations.
• Other organisations may also have Prevent duties if they perform delegated local authority functions.

Children can be exposed to different views and receive information from various sources. Some of these views may be considered radical or extreme.

Radicalisation is the process through which a person comes to support or be involved in extremist ideologies. It can result in a person becoming drawn into terrorism and is in itself a form of harm.

Extremism is vocal or active opposition to fundamental British values, including democracy, the rule of law, individual liberty and mutual respect and tolerance of different faiths and beliefs.

Reporting:

We will ensure that safe, appropriate, accessible means of reporting safeguarding concerns are made available to staff and the communities we work with.

Any staff reporting concerns or complaints through formal whistleblowing channels (or if they request it) will be protected by the Eligo Group of Companies Whistleblowing Policy.

We will also accept complaints from external sources such as members of the public, partners and official bodies.  

How to report a safeguarding concern

Staff members who have a complaint or concern relating to safeguarding should report it immediately to Aleks Dimitrova or line manager. If the staff member does not feel comfortable reporting to Aleks Dimitrova or line manager (for example if they feel that the report will not be taken seriously, or if that person is implicated in the concern) they may report to Victoria Bodhani, General Manager.  

Response:

We will follow up safeguarding reports and concerns according to policy and procedure, and legal and statutory obligations.

We will apply appropriate disciplinary measures to staff found in breach of policy.

We will offer support to survivors of harm caused by staff or associated personnel, regardless of whether a formal internal response is carried out (such as an internal investigation). Decisions regarding support will be led by the survivor.

Training and Awareness: 

We will ensure an appropriate level of safeguarding training is available to our Directors, Employees, Candidates, Volunteers and any relevant persons linked to the organisation who require it (e.g. contractors).

For all employees who are working or volunteering with adults at risk, children and young people, this requires them as a minimum to have awareness training that enables them to: 

• Understand what safeguarding is and their role in safeguarding adults at risk, children and young people.
• Recognise a child potentially in need of safeguarding and take action.
• Understand how to report a safeguarding Alert.
• Understand dignity and respect when working with adults at risk, children and young people.
• Have knowledge of our Safeguarding Policy.

Confidentiality and Information Sharing:

We expect all employees, candidates, volunteers and other personnel to maintain confidentiality. Information will only be shared in line with the General Data Protection Regulations (GDPR) and Data Protection Act 2018.

However, information should be shared with any relevant Local Authority if an adult at risk, child or young person is deemed to be at risk of harm or contact the police if they are in immediate danger, or a crime has been committed. 

Recording and Record Keeping:

A written record must be kept about any concern regarding an adult with safeguarding needs. This must include details of the person involved, the nature of the concern and the actions taken, decision made and why they were made.

All records must be signed and dated. All records must be securely and confidentially stored in line with General Data Protection Regulations (GDPR) and the Data Protection Act 2018. (see the Eligo Group of Companies Privacy Policy) 

Safe Recruitment & Selection:

We are committed to safe employment and safe recruitment practices, which reduce the risk of harm to adults at risk, children and young people from people unsuitable to work with them or have contact with them. 

We have policies and procedures that cover the recruitment of all directors, employees, candidates and volunteers. (see the Eligo Group of Companies Recruitment Policy).

Social Media:

All employees, candidates and volunteers should be aware of our social media policy and procedures (see the Eligo Group of Companies Employee Handbook) and the code of conduct for behaviour towards any adults at risk, children and young people we support.

 Use of Mobile Phones and other Digital Technology:

All employees, candidates and volunteers should be aware of our policy and procedures regarding the use of mobile phones and any digital technology and understand that it is unlawful to photograph adults at risk, children and young people without the explicit consent of the person with guardianship and/or parental responsibilities. (see the Eligo Group of Companies Employee Handbook)

Whistleblowing:

It is important that people within the Eligo Group of Companies have the confidence to come forward to speak or act if they are unhappy with anything. Whistleblowing occurs when a person raises a concern about dangerous or illegal activity, or any wrong- doing within their organisation. This includes concerns about another employee, candidate or volunteer. There is also a requirement by the Eligo Group of Companies to protect whistleblowers. This is more specifically dealt with in the Eligo Group of Companies Whistleblowing Policy.

Important Contacts:

Primary Contact for Safeguarding

Name: Aleks Dimitrova (Operations and Finance Manager)

Email address: aleksd@eligo.co.uk

Telephone number: 020 8944 4116 

Police

Emergency – 999

Non-emergency – 101

NSPCC Helpline

0808 800 5000

Introduction 

The Eligo Group of Companies (Eligo Recruitment Ltd, Eligo Security Ltd and Eligo Medical Ltd) is committed to providing a working environment free from bullying and harassment. We aim to ensure that all staff and candidates are treated, and treat others, with dignity and respect. This policy covers bullying or harassment which occurs at work and out of the workplace, including on work trips or at work-related events or social functions. This policy also covers all steps in the recruitment process, from initial contact with candidates through to placement. This policy applies to all staff at all levels including employees, management, agency and casual workers, candidates seeking employment through the Eligo Group and independent contractors. 

What is harassment? 

Harassment is any unwanted conduct that has the purpose or effect of violating a person's dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. A single incident can amount to harassment. A person may be harassed even if they were not the intended "target". Harassment also includes treating someone less favourably because they have submitted or refused to submit to such behaviour in the past. 

It is unlawful under the Equality Act 2010 to harass a person because of their age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation. 

It also includes conduct of a sexual nature (sexual harassment). 

Harassment is unacceptable even if it does not fall within any of these categories. 

Examples of harassment include, but are not limited to: 

• unwanted physical conduct including touching, pinching, pushing and grabbing; 

• unwelcome sexual advances or suggestive behaviour; 

• offensive e-mails, text messages or social media content or the display of offensive materials; 

• unwanted jokes, banter, mocking, mimicking or belittling a person. 

Remember what may seem to be harassment is determined in how the victim reacts to it, not how the perpetrator views it. What you may consider to be “banter” to another may be deeply offensive!

What is bullying? 

Bullying is offensive, intimidating, malicious or insulting behaviour, an abuse or misuse of power through means that undermine, humiliate, denigrate or injure the recipient. 

Bullying can include the use of personal strength or the power to coerce through fear or intimidation, not necessarily from someone in a position of authority. 

Bullying may be physical, verbal or non-verbal. It can include conduct that is not face-to-face, including via text message, email and social media. 

Examples of bullying include: 

• physical or psychological threats; 

• overbearing and intimidating levels of supervision; 

• inappropriate derogatory remarks about a person or their performance;

• shouting at one or more people, in a threatening, offensive or overbearing manner; 

• persistently picking on people in front of others or in private; 

• blocking promotion and training opportunities; 

• regularly and deliberately ignoring or excluding staff from work activities or work related social events; 

• setting a person up to fail by overloading them with work or setting impossible deadlines; 

• regularly making the same person the butt of jokes.

Legitimate and reasonable criticism of a staff member or candidate’s performance or behaviour, or reasonable management instructions, do not amount to bullying. 

Breaches of this Policy Bullying and harassment are not tolerated in our workplace and all staff are required to treat each other, along with our candidates, customers, suppliers, and visitors, with dignity and respect. 

Breaches of this policy will be dealt with in accordance with Section 7 of our Employee Handbook setting out our disciplinary procedure. 

Serious cases of bullying or harassment may amount to gross misconduct resulting in dismissal. 

Staff or candidates who make complaints or who participate in good faith in any investigation must not suffer any form of retaliation or victimisation as a result. However, making a false allegation deliberately and in bad faith will be treated as misconduct and dealt with under our disciplinary procedure. 

Anyone found to have retaliated against or victimised someone in this way will be subject to disciplinary action under our disciplinary procedure. 

If you believe you are being Harassed or Bullied 

If you believe you are being harassed or bullied, you may wish to raise the problem informally with the person responsible. Explain the situation and how it has made you feel. It can be helpful to describe the event so the other person is clear about your concerns. Use the opportunity to ask the person to change or stop their behaviour. 

Alternatively you may speak to your manager or account handler who can provide confidential advice and assistance in resolving the issue formally or informally. If you do not feel that informal steps are appropriate, or they have been unsuccessful, you should raise the matter formally under our grievance procedure in accordance with section 7 of our Employee Handbook.

All complaints will be investigated in accordance with our grievance procedure. 

If we consider that there is sufficient evidence to suggest you have been harassed or bullied we will consider the appropriate action to take. 

If the person accused is an employee, this may include invoking our disciplinary procedure. If the person accused is a candidate, this may include removing him or her from our candidate database. 

Whether or not your complaint is upheld, we will consider how best to manage any ongoing working relationship between you and the person concerned.