Anti-Bribery and Corruption Policy

1 Statement

Inspired PLC (“the Company”) is committed to the practice of responsible corporate behaviour and to complying with all laws, regulations and other requirements which govern the conduct of our operations.

The Company is fully committed to instilling a strong anti-corruption culture and is fully committed to compliance with all anti-bribery and anti-corruption legislation including, but not limited to, the Bribery Act 2010 (“the Act”) and has processes to ensure that no bribes or other corrupt payments, inducements or similar are made, offered, sought or obtained by us or anyone working on our behalf.

2 Bribery

Bribery is defined as the giving or promising of a financial or other advantage to another party where that advantage is intended to induce the other party to perform a particular function improperly, to reward them for the same, or where the acceptance of that advantage is in itself improper conduct.

Bribery is also deemed to take place if any party requests or agrees to receive a financial or other advantage from another party where that advantage is intended to induce that party to perform a particular function improperly, where the acceptance of that advantage is in itself improper conduct, or where that party acts improperly in anticipation of such advantage.

Bribery of a foreign official is defined as the giving or promising of a financial or other advantage which is intended to influence the official in order to obtain business or an advantage in the conduct of business unless the foreign official is required or permitted by law to be influenced by such advantage.

3 Consequences of bribery

Anyone or any organisation found guilty of bribery under the Act may face fines and/or prison terms. In addition, high legal costs and adverse publicity are likely to result from any breach of the Act.

For employees of the Company, failure to comply with this policy and/or with the Act may result in:

› Disciplinary action which may include dismissal; and

› Criminal penalties under the Act which may result in a fine and/or imprisonment for up to 10 years.

For the Company, any breach of this policy by any employee or business associate may result in the Company:

› Being deemed to be in breach of the Act;

› Being subject to fines; and

› Suffering negative publicity and further associated damage as a result of such breach.

4 Responsibility for compliance & scope of policy

This policy applies to all employees, agents, contractors, subcontractors, consultants, business partners and any other parties (including individuals, partnerships and bodies corporate) associated with the Company or any of its subsidiaries.

It is the responsibility of all of the above-mentioned parties to ensure that bribery is prevented, detected and reported and all such reports should be made in accordance with the Company’s Whistleblowing Policy or as otherwise stated in this policy, as appropriate.

No party described in the first paragraph of section 4 may:

› Give or promise any financial or other advantage to another party (or use a third party to do the same) on the Company’s behalf where that advantage is intended to induce the other party to perform a particular function improperly, to reward them for the same, or where the acceptance of that advantage will in itself constitute improper conduct;

› Request or agree to receive any financial or other advantage from another party where that advantage is intended to induce the improper performance of a particular function, where the acceptance of that advantage will in itself constitute improper conduct, or where the recipient intends to act improperly in anticipation of such an advantage.

Parties described in the first paragraph of section 4 must:

› Be aware and alert at all times of all bribery risks as described in this policy and in particular as set out in section 9 below;

› Exercise due diligence at all times when dealing with third parties on behalf of the Company; and

› Report any and all concerns relating to bribery to the Chief Executive, in the case of non-employees, their normal point of contact within the Company, or otherwise in accordance with the Company’s Whistleblower Protection Policy.

5 Facilitation payments

A facilitation payment is defined as a small payment made to officials in order to ensure or speed up the performance of routine or necessary functions.

Facilitation payments constitute bribes and, subject to the following paragraph, may not be made at any time irrespective of prevailing business customs in certain territories.

Facilitation or similar payments may be made in limited circumstances where your life is in danger but under no other circumstances. Any payment so made must be reported to the Managing Director as soon as is reasonably possible and practicable.

6 Gifts & hospitality

Gifts and hospitality remain a legitimate part of conducting business and should be provided only in compliance with the Company’s Gifts & Hospitality Policy.

Gifts and hospitality can, when excessive, constitute a bribe and/or a conflict of interest. Care and due diligence should be exercised at all times when giving or receiving any form of gift or hospitality on behalf of the Company.

The following general principles apply:

› Gifts and hospitality may neither be given nor received as rewards, inducements or encouragement for preferential treatment or inappropriate or dishonest conduct.

› Neither gifts nor hospitality should be actively sought or encouraged from any party, nor should the impression be given that the award of any business, custom, contract or similar will be in any way conditional on gifts or hospitality.

› Cash should be neither given nor received as a gift under any circumstances.

› Gifts and hospitality to or from relevant parties should be generally avoided at the time of contracts being tendered or awarded.

› The value of all gifts and hospitality, whether given or received, should be proportionate to the matter to which they relate and should not be unusually high or generous when compared to prevailing practices in our industry or sector.

› Certain gifts which would otherwise be in breach of this Policy and/or the Gifts & Hospitality Policy may be accepted if refusal would cause significant and/or cultural offence; however, the Company will donate any gifts accepted for such reasons to a charity of the Managing Director’s choosing.

› All gifts and hospitality, whether given or received, must be recorded in the Gifts & Hospitality Register.

7 Charitable donations

Charitable donations are permitted only to registered (non-profit) charities. No charitable donations may be given to any organisation which is not a registered charity.

All charitable donations must be fully recorded with the Accounts Team.

Proof of receipt of all charitable donations must be obtained from the recipient organisation.

Under no circumstances may charitable donations be made in cash.

No charitable donation may be made at the request of any party where that donation may result in improper conduct.

8 Political donations

The Company does not make political donations and the Company is not affiliated with any political party, independent candidate, or with any other organisation whose activities are primarily political.

Employees and other associated parties are free to make personal donations provided such payments are not purported to be made on behalf of the Company and are not made to obtain any form of advantage in any business transaction.

9 Due diligence & risks

The following issues should be considered with care in any and all transactions, dealings with officials, and other business matters concerning third parties:

› Territorial risks, particularly the prevalence of bribery and corruption in a particular country;

› Cross-border payments, particularly those involving territories falling under the previously stated issue;

› Requests for cash payment, payment through intermediaries or other unusual methods of payment;

› Activities requiring the Company and/or any associated party to obtain permits or other forms of official authorisation;

› Transactions involving the import or export of goods.

Date1st March 2021
Next Review DateAnnually or at point of incident
Approved and Authorised
NameMark Dickinson
PositionChief Executive Officer

Anti-Discrimination Policy

1 Statement

Our Anti-discrimination policies require employees to sign formal contracts of employment that require them to abide by company policy at all times. These policies are set out in a comprehensive Staff Handbook. The following sections detail our Anti-discrimination policies and reflect the latest copy of the Staff Handbook.

2 Equal Opportunities
2.1 What does this mean?

The Company is committed to providing and promoting opportunities for staff and job applicants. We are committed to creating a working environment which enables everyone to work to the best of their skills and abilities and without the threat of discrimination or harassment arising. As a Company we pride ourselves on treating all members of staff equally, irrespective of their or their “Associated Persons” gender, sex, pregnancy or maternity status, marital status, race, colour, religion or belief, disability, age, sexual orientation, gender reassignment (“Protected Characteristics”). An Associated Person may be a member of staff’s family, friends or other dependants.

Whilst the Company is committed to treating all employees equally, the success of this policy requires equal input from all employees.

All employees are required to comply with their obligations to promote a working environment free from discrimination. You should treat your colleagues, customers and members of the public as you would expect to be treated yourself and respect the Protected Characteristics of others.

2.2 Does this apply to the recruitment process?

We aim to ensure that no job applicant suffers from discrimination of any form during the recruitment process. Our application and interview process are reviewed regularly to ensure that they do not put any particular group at a disadvantage.

We will not ask unnecessary questions about an applicant’s personal affairs during the recruitment process. Questions about a prospective employee’s health will usually be left until the offer stage unless the questions are raised to identify any particular needs for the recruitment process, for a genuine occupation need or because we wish to establish at the outset the ability of a candidate to perform an intrinsic feature of the job i.e. heavy lifting.

As part of the recruitment process, we will require all prospective employees to produce appropriate ID (originals must be produced) to demonstrate that individual’s legal right to
work in the UK before employment is allowed to commence.

We may, as part of any equal opportunities monitoring programme, request job applicants to complete an Equal Opportunities Form which will be detachable from the main application and used solely for the purpose of monitoring equal opportunities.

2.3 What is discrimination?

Discrimination can take a number of different forms:

Treating someone less favourably because of one or more protected Characteristic i.e. rejecting a job applicant because they are a different race or are pregnant. This is known as direct discrimination.

Applying an unjustified provision, criterion or practice which, although applied equally across all employees or job applicants, places some individuals with a particular Protected Characteristic, at a disadvantage i.e. requiring job applicants to have 10 years’ driving experience would prevent individuals under the age of 27 from applying for the role. Unless this requirement for 10 years’ driving experience can be justified this will be an act of indirect discrimination.

Bullying or harassment - see section 5 below.

Treating someone less favourably because they have raised a complaint of discrimination or given information about discrimination or supported a colleague's complaint. This is known as victimisation.

There are additional acts of discrimination which extend to staff who suffer from a disability (whether mental or physical).

The law governing equality within the workplace extends protection to members of staff who have an association with a person with a Protected Characteristic. For example, an act of discrimination may arise where a staff member is harassed or feels harassed because they have a child who is disabled.

You should also be aware that protection is extended to those who are “perceived” to have a Protected Characteristic but in fact don’t. For example, subjecting a member of staff to homophobic banter because it is perceived, albeit incorrectly, that the member of staff is not heterosexual.

Although discrimination may appear to be complicated, members of staff are unlikely to breach our policy and the law as long as they treat all colleagues with respect and dignity regardless of a person’s Protected Characteristics.

No one will be denied access to training or promotion on grounds of any Protected Characteristics.
4.3.6 No member of staff will have their employment or engagement terminated because of a Protected Characteristic.

Access to services, benefits and facilities will be made available to all staff equally having regard to their grade or position.

2.4 Will reasonable adjustments be made if I have a disability?

If an applicant is unable to attend an interview or other recruitment stage for any reason, we will consider any reasonable adjustments that may assist the applicant in participating fully in the recruitment process and being given an equal opportunity to be considered for any vacancy.
Similarly, as an employee of the Company, we encourage you to discuss any condition you may have with us so that we can help you overcome or minimise any difficulty you may be experiencing in the workplace (whether a physical feature or compliance with a policy or procedure) or in the performance of your duties. This will allow the Company to explore any reasonable adjustments that could be made to keep you in employment or, where absent from work, to facilitate a return to work.

2.5 Will I receive training on equal opportunities?

As part of the induction process, you will be provided with suitable training concerning equal opportunities.

We will monitor staff training needs and where a training gap is identified, all staff will be given access to suitable training to ensure they are fully aware of their obligations.

If any member of staff feels they require additional support and training in this area, they should contact their line manager accordingly.

3 Anti-bulling
3.1 How does this policy affect me?

The Company is committed to ensuring that all members of staff are treated with dignity and respect regardless of whether they have a Protected Characteristic (as explained in Section 4 above) or not. Where an employee feels that they have been subjected to harassment and bullying, they should draw such matters to the attention of their line manager.

The Company takes all allegations of bullying and harassment with the upmost seriousness and where the allegations are proven to be true, the employee at fault will be subject to our disciplinary process.

Harassment and bullying is a misconduct offence, however where it is sufficiently serious, this will be categorised as gross misconduct which may lead to your dismissal. Each case will be considered on its own facts.

3.2 What is harassment?

Harassment is any unwanted physical, verbal or non-verbal conduct which has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. This can also involve matters such as offensive jokes through to conduct of a sexual nature (i.e. unwanted sexual advances) and need only be a single incident. Harassment need not be on grounds of a Protected Characteristic. As such, unwanted conduct directed at an individual because of their weight would also be caught by the policy.

It does not matter if you did not intend to cause offence, although this may be relevant as to the severity of the matter. What matters is the effect it has on the recipient of the unwanted treatment.

3.3 What is bullying?

Bullying is categorised as offensive, intimidating, malicious or insulting behaviour involving the misuse of power that can leave an employee feeling vulnerable, upset, humiliated, undermined or threatened.

3.4 How do I raise a complaint?

Initially, it may be possible for you to raise this issue informally with the person responsible for the unwanted behaviour. Sometimes that person maybe unaware that their behaviour is causing offence to you (i.e. rude jokes) and may genuinely be upset to learn they have caused offence. Where you are able to do so, you should explain to the employee that their behaviour is not welcomed and makes you uncomfortable and could they avoid such behaviour in the future. Make a note of any conversation you have with the person involved.

If you are unable to deal with this issue informally, you can raise a formal complaint in writing with your line manager. Your complaint should set out the full details of the unwanted conduct and include dates, times, locations, and the names of any witnesses to the unacceptable behaviour.

We will treat all complaints made with the strictest confidence and will look to investigate the issue in a prompt and timely manner.

3.5 Will a formal investigation take place?

The Company takes all complaints of bullying and harassment seriously and we will look to deal with any complaints in a timely manner.

We will undertake an investigation into the allegations and all investigations will be thorough, impartial and objective. In order to discuss the outcome of your investigation, we will invite you to a meeting within 7 days of receiving your complaint. You have the right to be accompanied to this meeting by either a fellow colleague or a Trade Union Representative.

Where your complaint relates to a fellow colleague, we will consider whether suspension on full pay or alterations to the employee’s working arrangements, pending the outcome of the investigations, is necessary.

At the conclusion of our investigation, the investigating officer will submit their report to a senior manager who will consider the matter further.
A further meeting will be scheduled with you within 7 days of receipt of this report so that we can discuss the outcome of the investigation and any proposed action. Again, you have the right to be accompanied by a fellow colleague or a Trade Union Representative.

3.6 What action may be taken?

Where the senior manager considers that an offence has occurred, the manager will take prompt action to resolve the issue.
Where the harasser or bully is a fellow employee, we will look to deal with the potential misconduct or gross misconduct offence under our disciplinary procedure. However, the outcome of the disciplinary process is a matter for the Company to determine. The aggrieved cannot dictate what action is to be taken.

The Company may explore, in certain cases, the feasibility of mediation between the harasser and the aggrieved. This may be accompanied by additional training for the harasser, either internally or externally. All staff are encouraged to consider engaging in mediation where it is offered as a solution, although the Company recognises that mediation will not always be appropriate.

Where the unwanted behaviour has stemmed from a third party, we will look to clarify the behaviour expected of their representatives or in very serious cases, ban them from our premises and/or terminate the contract with them.

Please note that any employee who deliberately provides false information or acts in bad faith as part of the investigation process, will be subject to action under the disciplinary procedure.

3.7 If I am unhappy with the outcome, do I have a right to appeal?

If you are unhappy with the outcome of the investigation, you may appeal in writing to a director within 7 days. In submitting your appeal, you should state the full grounds upon which your appeal is based.

The Company will schedule an appeal meeting with you within 7 days of receiving your letter and the appeal will be dealt with by an impartial manager who has not previously been involved with the investigation.

Again, you will be entitled to be accompanied to this meeting by a fellow employee or a Trade Union Representative.

Following this meeting, the Company will confirm its decision to you in writing within 7 days of the appeal hearing after which you will have no further right of appeal.

Date1st March 2021
Next Review DateAnnually or at point of incident
Approved and Authorised
NameMark Dickinson
PositionChief Executive Officer

Board Gender Diversity Policy

1 Statement

We recognise that having a board composed of men and women with the relevant blend of differing skills, experience, perspectives, age and characteristics, leads to a more robust understanding of opportunities, issues and risks; stronger decision-making; and are better equipped to provide oversight and governance.

We are committed to improving the gender representation of our board, and commit to working diligently to implement concrete actions to effect change. We will:

› Set measurable objectives to achieve better gender diversity.

› Ensure the board’s composition considers the balance of skills, experience, perspectives and characteristics in alignment with the strategic needs of the business and the environment in which it operates. In doing so, the board will consider all measurable objectives for improving gender diversity and make recommendations to the board.

› When recruiting new directors, the board will search beyond the networks of existing board members, and commit to using outside help until such times as the diversity objectives are achieved.

› If using a search firm, the nominating committee will direct the search consultant to deliver a gender-balanced slate of ‘equally qualified’ potential candidates. If for any reason, the search firm indicates that it cannot provide a gender balanced slate the board will request that the firm produce a detailed written report as to why it couldn’t and the exact process the search firm engaged in to find such candidates.

2 Objective

We undertake to ensure that by the by 31st December 2022, to have a board composition where each gender represents at least 37.5% and maintain this level into the future.

3 Board Gender Diversity Policy Review

The ESG Performance Committee will review this policy annually including an assessment of its effectiveness, and will discuss any revisions that may be required and recommend any such revisions to the board for approval.

Date1st March 2021
Next Review DateAnnually or at point of incident
Approved and Authorised
NameMark Dickinson
PositionChief Executive Officer

Climate Change and the Environment Policy

1 Statement

At Inspired PLC we believe that businesses are responsible for achieving good environmental practice and operating in a sustainable manner.

We are therefore committed to reducing our environmental impact and continually improving our environmental performance as an integral and fundamental part of our business strategy and operating methods.

We shall disclose our environmental and sustainability performance through disclosures with respect to Streamlined Energy and Carbon Reporting (SECR) and the Taskforce on Climate Related Financial Disclosures (TCFD)

As a business we acknowledge and accept there is a climate emergency, and we are committed to assessing the risks and opportunities of climate impacts on our business strategy, disclosing them and taking actions to minimise them.

It is our priority to encourage our customers, suppliers and all business associates to do the same. Not only is this sound commercial sense for all but it is also a matter of delivering on our duty of care towards future generations. Our policy is to:

› Wholly support and comply with or exceed the requirements of current environmental legislation and codes of practice.

› Implement improvements to reduce our waste and increase the reuse and recycling of such waste.

› Reduce energy and water usage in our buildings, vehicles and processes in order to conserve supplies, and optimise our consumption of natural resources, especially where they are non-renewable.

› Operate and maintain company vehicles (where appropriate) with due regard to environmental issues as far as reasonably practical and encourage the use of alternative means of transport such as public transport, cycling and walking to work and car sharing as appropriate.

› We promote the use of travel alternatives such as e-mail or video/phone conferencing.

› We apply the principles of continuous improvement in respect of air, water, noise and light pollution from our premises and reduce any impacts from our operations on the environment and local community.

› As far as possible we purchase products and services that do the least damage to the environment and encourage others to do likewise.

› We prioritise the use of local labour and materials where available to reduce CO2 emissions and help the community both economically and environmentally.

› Increase the use of environmentally friendly cleaning materials where possible.

› When refurbishing our offices, we aim to maximise the use of many environmentally friendly materials as possible.

› We use only licensed and appropriate organisations for waste disposal purposes.

› We assess in advance the environmental impact of any new processes or products we are considering introducing.

Date1st March 2021
Next Review DateAnnually or at point of incident
Approved and Authorised
NameMark Dickinson
PositionChief Executive Officer

Complaint Process Policy

1 Statement


We are committed to providing exceptional client service and set clear standards for customer care. As a business we undertake to comply with all legislation and applicable standards, relevant to our business and services.

2 Responsibilities


Our Board of Directors is responsible for reviewing and approving this policy and ensuring its implementation. Our managers are required to check that their direct reports understand this policy and implement its requirements.

3 Exclusions


Our policy excludes and is without prejudice to the following:

> complaints from employees, who should utilise their rights under the company’s discipline and grievance policies and general rights as determined by the legal system.
> complaints relating to contractual disputes where complainants should use their rights under their agreed contract and the legal system.

4 Complaint Policy

We view complaints seriously and will endeavour to resolve and learn from all complaints fairly, pragmatically and appropriately for the person or organisation concerned in accordance with the Complaint procedure.

We will endeavour to resolve your complaint to your satisfaction; however, we recognise that this will not always be possible and we reserve all of our rights.

In the event that we cannot resolve your complaint we will refer you to your legal advisor.

All complaint information is handled in accordance with the General Data Protection Regulation.

5 Complaints Procedure

  1. Complaint is emailed to [email protected] or raised directly to a member of staff where it is clearly identified as a matter of complaints.
  2. Complaint Owner will contact you and acknowledge within five business days and seek a resolution target within four weeks. If the complaint is not resolved there will be an escalation to the Senior Management team.
  3. If the complaint cannot be resolved by the Senior Management team we will either escalate your complaint to the Board of Directors where appropriate or refer you to your legal advisor.
  4. If the complaint is escalated to the board of directors and cannot resolved by the Board of Directors we will refer you to your legal advisor.
Date1st March 2021
Next Review DateAnnually or at point of incident
Approved and Authorised
NameMark Dickinson
PositionChief Executive Officer

Employee Gender Diversity & Equal Pay Policy

1 Statement

We recognise that a gender diverse workforce, not only provides a workforce that is more representative of society but can also deliver a number of other benefits, including:

› Access to a wider talent pool.

› Differing perspective, points of view and approaches that come from different life experiences. A multiplicity of perspectives can spark creativity and innovation and can help us identify new opportunities.

› It can encourage challenging gender stereotypes.

› Diverse teams can help improve team processes and boost group collaboration.

› Having an inclusive workplace is a powerful recruiting tool. Research shows many millennials look for employers with a strong record on diversity.

We are committed to improving the gender representation each level of our organisation. We will:

› set measurable objectives to achieve better gender diversity.
› publish our performance with respect to employee gender diversity annually.
› providing a keep in touch program for employees on parental level.
› conducting skill analysis to ensure the skills of women and men are valued.
› providing for training and development opportunities to be available to all.
› monitoring and analysing exits by gender to understand the reasons for employees staying and leaving.

Equal pay between men and women is a legal right between all employees. We are committed to the principle of equal pay and other contractual terms for all employees with equivalent experience, in similar roles, operating in equivalent circumstances. We will:

› Eliminate any unfair, unjust or unlawful practices which impact on pay.

› ensure no structural difference in contract terms or offers of remuneration with respect to gender.

› Publish the ratio of pay by gender to the average pay for each category of role within the organisation.

› Set targets for out turn pay equivalency which recognise that there are other factors that will lead to differentials in pay between employees but in all cases such factors should not lead to a material difference.

› Monitor pay practices and statistics annually and systematically review processes to remove gender bias from our pay system.

This policy is separate to the company’s policy on equal opportunities and diversity which can be found on our website.

2 Objective

We aim to operate a company where each gender represents at least 37.5% of the workforce and maintain this level into the future. Specifically, we undertake to achieve this level in our Senior Leaders and Operational Leaders by 31st December 2023.

We aim to have no more than a 15% difference between the pay for any gender from the average pay for an employee, of similar experience, in a similar role operating in similar circumstances.

3 Employee Gender Diversity Policy Review

This policy shall be reviewed annually including an assessment of its effectiveness.

Date1st March 2021
Next Review DateAnnually or at point of incident
Approved and Authorised
NameMark Dickinson
PositionChief Executive Officer

Equal Opportunities and Diversity Policy

1 Statement

We promote a working environment in which diversity is recognised, valued and encouraged. We acknowledge the multicultural and diverse nature of the workforce and society. We are committed to principles of fairness and mutual respect where everyone accepts the concept of individual responsibility.

All staff receive the company handbook which sets out a comprehensive equal opportunities policy and additional information on bullying and harassment and the internal procedures to raise a query or report an issue with respect to these matters.

It is the responsibility of staff and the board of directors to make sure they observe and adhere to this policy at all times. We view any breach seriously. We will investigate and potentially take disciplinary action. This may include dismissal in instances we consider gross misconduct.

We recognise that discrimination in the workplace in any form is unacceptable and in most cases unlawful. Our policy seeks to ensure job applicants and employees are treated fairly and without
favour or prejudice. We are committed to applying this throughout all areas of employment. This includes recruitment and selection, training and development, benefits, rewards and promotion, dealing with grievances and disciplinary issues.

Our policy complies with current legislation. We review it regularly and will update it if the law changes. All changes are reflected in our staff handbook that is in addition reviewed annually or as required, whichever is soonest. However, we recognise that equality of opportunity is best achieved by day-to-day commitment from everyone. We offer support and training where necessary to achieve and maintain this.

This is a group wide policy and applies to all subsidiaries within Inspired PLC.

The Company is committed to providing and promoting opportunities for staff and job applicants. We are committed to creating a working environment which enables everyone to work to the best of their skills and abilities and without the threat of discrimination or harassment arising. As a Company we pride ourselves on treating all members of staff equally, irrespective of their or their “Associated Persons” gender, sex, pregnancy or maternity status, marital status, race, colour, religion or belief, disability, age, sexual orientation, gender reassignment (“Protected Characteristics”). An Associated Person may be a member of staff’s family, friends or other dependants.

Whilst the Company is committed to treating all employees equally, the success of this policy requires equal input from all employees. All employees are required to comply with their obligations to promote a working environment free from discrimination. You should treat your colleagues, customers and members of the public as you would expect to be treated yourself and respect the Protected Characteristics of others.

2 Recruitment Process

We aim to ensure that no job applicant suffers from discrimination of any form during the recruitment process. Our application and interview process are reviewed to ensure that they do not put any particular group at a disadvantage.

We will not ask unnecessary questions about an applicant’s personal affairs during the recruitment process. Questions about a prospective employee’s health will usually be left until the offer stage unless the questions are raised to identify any particular needs for the recruitment process, for a genuine occupation need or because we wish to establish at the outset the ability of a candidate to perform an intrinsic feature of the job i.e. heavy lifting.

As part of the recruitment process, we will require all prospective employees to produce appropriate ID (originals must be produced) to demonstrate that individual’s legal right to work in the UK before employment is allowed to commence.

We may, as part of any equal opportunities monitoring programme, request job applicants to complete an Equal Opportunities Form which will be detachable from the main application and used solely for the purpose of monitoring equal opportunities.

3 Discrimination

Discrimination can take a number of different forms:

a) Treating someone less favourably because of one or more Protected Characteristic i.e. rejecting a job applicant because they are a different race or are pregnant. This is known as direct discrimination.

b) Applying an unjustified provision, criterion or practice which, although applied equally across all employees or job applicants, places some individuals with a particular Protected Characteristic, at a disadvantage i.e. requiring job applicants to have 10 years’ driving experience would prevent individuals under the age of 27 from applying for the role. Unless this requirement for 10 years’ driving experience can be justified this will be an act of indirect discrimination.

c) Bullying or harassment.

d) Treating someone less favourably because they have raised a complaint of discrimination or given information about discrimination or supported a colleague’s complaint. This is known as victimisation.

e) There are additional acts of discrimination which extend to staff who suffer from a disability (whether mental or physical).

The law governing equality within the workplace extends protection to members of staff who have an association with a person with a Protected Characteristic. For example, an act of discrimination may arise where a staff member is harassed or feels harassed because they have a child who is disabled. You should also be aware that protection is extended to those who are “perceived” to have a Protected Characteristic but in fact don’t. For example, subjecting a member of staff to homophobic banter because it is perceived, albeit incorrectly, that the member of staff is not heterosexual.

Although discrimination may appear to be complicated, members of staff are unlikely to breach our policy and the law as long as they treat all colleagues with respect and dignity regardless of a person’s Protected Characteristics.

No member of staff will be denied access to training or promotion on grounds of any Protected Characteristics.

No member of staff will have their employment or engagement terminated because of a Protected Characteristic.

Access to services, benefits and facilities will be made available to all staff equally having regard to their grade or position.

4 Ability Adjustments

If an applicant is unable to attend an interview or other recruitment stage for any reason, we will consider any reasonable adjustments that may assist the applicant in participating fully in the recruitment process and being given an equal opportunity to be considered for any vacancy.

Similarly, as an employee of the Company, we encourage you to discuss any condition you may have with us so that we can help you overcome or minimise any difficulty you may be experiencing in the workplace (whether a physical feature or compliance with a policy or procedure) or in the performance of your duties. This will allow the Company to explore any reasonable adjustments that could be made to keep you in employment or, where absent from work, to facilitate a return to work.

5 Training

As part of the induction process, staff are provided with suitable training concerning equal opportunities.

We will monitor staff training needs and where a training gap is identified, all staff will be given access to suitable training to ensure they are fully aware of their obligations.
If any member of staff feels they require additional support and training in this area, they should contact their line manager accordingly.

Date1st March 2021
Next Review DateAnnually or at point of incident
Approved and Authorised
NameMark Dickinson
PositionChief Executive Officer

Health and Safety and Accident Prevention Policy

1 Health & Safety & Accident Prevention Policy

This section details the arrangements for the effective management of health and safety within Inspired PLC and covers all corporate subsidiaries as listed on the UK Companies House register.

A copy of our current general statement of health and safety and accident prevention policy can be found in Part 1. This sets out our commitment to provide and maintain safe working conditions for our employees and others who may be affected by our activities.

We will ensure that the objectives of this statement are communicated to our employees, initially through our induction training and our Employee Handbook. We will also monitor progress towards these objectives at senior management level and we will review them annually in consultation with our employees and other interested parties.

The policy is supported by our health and safety management system which details our arrangements for the effective management of our significant risks and exposures. This includes detailed policies and procedures, our process for assessing risk, and our arrangements for emergencies, fire and first aid etc.

To meet the objectives of our health and safety and accident prevention policy we have established and implemented clear responsibilities for health and safety; see the chart in Part 2.

We are aware that senior managers within the company are individually and collectively responsible for health and safety. Therefore, specific responsibility for health and safety has been assigned to Nick Bell (see Part 3). We have appointed Nick as the person with overall responsibility for health and safety.

Nick is responsible for managing health and safety matters on a day-to-day basis; Nick and Andrea Clay (Group Office Manager) may also be assisted by local Managers as delegated. Nick will manage our health and safety programme, ensuring that all the essential elements of the system are implemented, monitored and reviewed including management of third-party expertise that the company brings in for advisory services. However, we are aware that we can only meet our objectives through the efforts of our employees; therefore, we have established clear lines of communication and encourage our employees to co-operate with us in achieving our objectives.

We have established a clear policy on consultation. We recognise that the key to successful health and safety management is to ensure each employee is competent to carry out their responsibilities. To this end we have developed and implemented a training policy which clearly defines who is responsible for training and identifies what training each individual needs, based on the results of our risk assessments. Each individual's training requirements are identified in a training matrix, and this is supported by general responsibilities contained in the Health and Safety Handbook and individual work instructions for specific tasks and processes.

2 Part 1 - Health & Safety - General Statement of Intent

The following is produced in pursuance of the company's obligations under, Section 2 (3) of the Health and Safety at Work Act 1974.

Inspired PLC recognises and accepts its responsibilities as an employer for providing a safe and healthy workplace and environment for all its employees. The company will take all reasonable and practicable steps to ensure that the Health, Safety and Environment considerations affecting the general public and any other persons who may be affected by its activities are controlled.

The company will take all steps within its power, so far, as is reasonably practicable to meet this responsibility, and undertake all risk assessments as required under the Management of Health and Safety at Work Regulations 1999 and Management of Health and Safety Miscellaneous Amendments) Regulations 2002.

All employees must abide by the company's policy and the organisation and arrangements for implementing the policy and must accept and carry out their individual responsibilities to ensure work is carried out in a safe and environmentally responsible manner. Inspired PLC recognises that this safety policy cannot be successful without the active participation and commitment of all staff and must be observed by all members of staff at all times.

Whilst the Management of the Company accepts its prime responsibilities for ensuring the Health and Safety of its employees, it is required that all employees accept and fulfil their duties under Section 7 and 8 of the Health and Safety at Work Act 1974 wherein they are required:

a) To take all reasonable care for their own Health and Safety and that of others who may be affected by their acts or omissions.
b) To co-operate with Management to enable them to fulfil any statutory requirements.
c) Not to interfere with or misuse anything provided for their Health and Safety.

The Health and Safety at Work Act 1974 and The Management of Health and Safety at Work Regulations 1999 and all associated statutory legislation and any Work Rules or Procedures must be complied with at all times. All employees must contribute to making the Company's work areas as safe and environmentally friendly possible.

The company will take all steps under their control to comply with The Workplace (Health, Safety and Welfare) Regulations 1992 so far, as is reasonably practicable to ensure the health, safety and welfare of employees whilst at work. This will include the providing of a safe and healthy workplace, working environment including access and egress routes and welfare facilities.

Effective communication is essential for the achievement and maintenance of high standards. Good communication involves the flow of relevant communication in all directions throughout the company. All employees, irrespective of their position and responsibilities have an important part to play in communicating effectively.

The company’s policy statement will be reviewed and added to or modified from time to time in respect of new legislative changes and may be supplemented in appropriate cases by further statements relating to the work of a particular section(s) or groups of employees. The Board of Directors will give their full support to all those who endeavour to implement and carry out the Company Policy.

3 Part 2 - Organisation and specific responsibilities

The simple organisational chart below shows the company's arrangements for managing health and safety. This document is provided purely for health and safety purposes and does not necessarily represent the organisation for other business activities. It is supported by the specific responsibilities detailed further in this section.

The following responsibilities have been assigned to competent people to enable us to meet the objectives of our health and safety and accident prevention policy.

3.1 Mark Dickinson – Chief Executive Officer

The CEO has overall responsibility for the formulation and implementation of the company's health and safety and accident prevention policy, and in particular for:

› Ensuring that the necessary arrangements are in place for managing health and safety effectively, and that senior managers are accountable for health and safety.
› Considering health and safety during the planning and implementation of business strategy.
› Ensuring there are sufficient resources for meeting the objectives of the health and safety and accident prevention policy.
› Ensuring arrangements are in place for consultation with employees and that they are involved in decisions relating to health and safety, and that progress in relation to health and safety is communicated to them.
› Including health and safety on the agenda of Board meetings and senior executive meetings.
› Ensuring arrangements are in place to monitor and review health and safety performance across the company, including accidents and incidents; and ensuring that the necessary amendments are made to relevant policies, procedures and processes.
› Reviewing the objectives of the health and safety and accident prevention policy on an annual basis.

3.2 Employees

It is the duty of all employees to take all reasonable care for the health and safety of themselves, and any other persons who may be affected by their acts or omissions at work. They must also co-operate with senior managers and other employees in fulfilling our objectives and statutory duties, and in particular:

› Comply with the training, information and instruction they have been given.
› Not attempt to carry out hazardous work or use hazardous machinery unless they have been trained and authorised to do so.
› Carry out their work safely and without undue risk to themselves, colleagues and others who may be affected by their actions, and not intentionally interfere, misuse or ignore arrangements, controls and items provide for health and safety purposes.
› Check tools and equipment before using them, and not to use equipment which they know to be faulty.
› Ensure that any damaged equipment is reported immediately to their manager/supervisor and removed from service until it is repaired.
› Not bring any equipment, tools, radios, etc. onto company premises without first obtaining permission from their supervisor/manager.
› Conduct themselves in a responsible manner while on company business, be alert for hazards and refrain from any form of horseplay.
› Comply with the arrangements for emergencies and fire as they have been instructed.
› Use the personal protective equipment, clothing or safeguards provided and ensure that personal protective equipment is stored correctly and kept in good condition.
› Co-operate with management, colleagues, safety representatives and advisers promoting safe working practices.
› Keep their work areas tidy and clear of hazards.
› Report accidents, incidents and hazards they observe to their manager/supervisor.

This content is included in our Employee Handbook

3.3 Natalie Heseltine – Senior HR Business Partner

Is responsible for, in addition to any duties set out in this document or elsewhere, assisting in meeting the objectives of the health and safety and accident prevention policy, and in particular:

› Monitoring and reviewing the implementation of the health and safety and accident prevention policy.
› Ensuring that safety risk assessments are provided for all significant employee activities and the results of these assessments are implemented and communicated to employees.
› Ensuring that health risk assessments are provided for all employee situations and the results of these assessments are implemented and communicated to employee.
› Ensuring that relevant employee policies, procedures, and safe working practices are provided.
› Ensuring that the arrangements for communication, cooperation and consultation are maintained.
› Promptly informing the Board and senior managers of any significant health and safety failure.

3.4 Andrea Clay – Group Office Manager

› Investigating accidents and incidents and ensure that any improvements identified in relation to working practices are implemented and informing senior management immediately of any significant failures.
› Monitoring health and safety standards on site at regular intervals and ensure remedial action is implemented.
› Ensuring that health and safety records and documentation are complete and are systematically stored.
› Ensuring that employees receive adequate training, information, instruction and supervision to discharge to their specific health and safety responsibilities..
› Ensuring employees under their control comply with relevant health and safety legislation and follow approved procedures and safe systems of work.
› Ensuring that the arrangements for fire, first aid, accidents and emergencies are implemented.
› Ensuring that contractors are competent for the work they carry out, to operate an effective permit to work system, and to monitor contractors' performance.
› Ensuring that appropriate procedures are in place for the purchase, maintenance and use of work equipment, and that the health and safety aspects are fully assessed.
› Ensuring personal protective equipment is provided, worn and maintained.
› Implementing the recommendations made by external auditors, enforcement officers and other relevant parties, within the timescales allocated.

3.5 Andrea Clay – Fire Wardens

Fire Wardens are responsible for, in addition to any duties set out in this document or elsewhere assisting in meeting the objectives of the health and safety and accident prevention policy, and in particular:
› Being familiar with the emergency procedures.
› Taking appropriate and effective action if a fire occurs.
› Identifying hazards in the workplace and recording and report their observations.
› Ensuring that escape routes and doors are kept clear and are available for use.
› Ensuring fire doors are kept closed.
› Checking suitable and sufficient notices are displayed.
› Ensuring appropriate extinguishers are in place and are subject to regular maintenance.
› Ensuring fire alarms and emergency lighting is checked and serviced.
› If a fire is discovered, the fire wardens should:
› Ensure that the alarm has been raised.
› Check that manufacturing processes have been made safe.
› Collect roll call register.
› Evacuate staff from the building or area involved and check that any staff or visitors with disabilities are assisted as planned.
› Ensure the fire service has been called.
› Go to the designated assembly point.
› Conduct a roll call.
› Ensure all persons have been accounted for and remain in the roll call area until instructed otherwise.
› Report to the senior manager to confirm all persons are accounted for and report any persons missing.

FIRE WARDENS MUST NEVER PUT THEMSELVES AT RISK WHILE UNDERTAKING THEIR ROLE

3.6 Andrea Clay – First Aiders

First Aiders are responsible for, in addition to any duties set out in this document or elsewhere, assisting in meeting the objectives of the health and safety and accident prevention policy, and in particular:

› Being familiar with the emergency procedures and ensuring suitable and sufficient notices are displayed detailing the procedures.
› Maintaining a valid first aid at work certificate issued by an approved awarding body
› Attending appropriate additional courses to maintain their expertise as required remain up to date on the latest treatments.
› Being aware of the various hazards likely to be the cause of injury and the appropriate first-aid treatment necessary.
› Taking charge when someone is injured or falls ill and providing treatment or advice within the limits of their training and experience and referring any cases of doubt to a hospital or doctor.
› Checking that appropriate and sufficient first-aid boxes are sited about the premises and they are properly stocked and maintained.
› Checking that appropriate and sufficient eye wash facilities are sited about the premises and maintained.
› Recording details of all accidents and treatments in the appropriate incident log.
› Ensuring the Relevant Manager is advised of all accident and incidents to ensure the appropriate investigations can be completed.

3.7 Nick Bell – Director: Compliance and Integration

Is responsible for, in addition to any duties set out in this document or elsewhere, the day to day management of health and safety and ensuring that the objectives of the health and safety and accident prevention policy are implemented, and in particular:

› Ensuring that health and safety is considered prior to the implementation of new processes.
› Ensuring that suitable policies and procedures are provided and implemented to meet the objectives of the health and safety and accident prevention policy.
› Ensuring that there is a training policy in place so that employees are competent for their respective roles and their health and safety responsibilities.
› Ensuring that arrangements are in place for the elimination or control of risks in relation to health and safety.
› Ensuring suitable emergency arrangements are in place in relation to fire, accidents and first aid.
› Ensuring that the health and safety management system is implemented.
› Ensuring that responsibilities for health and safety are clearly allocated,
› Ensuring suitable controls are in place for the effective management of contractors.
› Ensure that reports and recommendations provided by enforcement bodies, external consultants and other such bodies are evaluated and actioned without delay.
› Management of third party Health and Safety providers, including the competent person and advisory service from Bill Rogerson Safety Services Ltd.
› Monitoring performance in relation to health and safety and reporting to the Chief Executive Officer and the Board of progress against the objectives of the health and safety and accident prevention policy and providing the Board with regular reports on health and safety performance, including recommendations for improvements.
› Reviewing accidents and other incidents in relation to health and safety and reporting to the Chief Executive Officer and the Board on the outcome of these investigations.
› Informing the Chief Executive Officer of any situation which may affect or incur adverse publicity.


Part 3 – Arrangements

Inspired PLC have Policies and Procedures in place to ensure that the following are managed and controlled:
› Risk Assessment
› COVID-19
› COSHH
› Fire
› First Aid
› Manual Handling
› Display Screen Equipment
› Training
› Consultation
› Equipment
› Electricity
› Welfare
› Management of Contractors

Date1st March 2021
Next Review DateAnnually or at point of incident
Approved and Authorised
NameMark Dickinson
PositionChief Executive Officer

Human Rights Policy


1 Statement

Inspired is committed to the highest standards of business and ethical behaviour including compliance with all applicable laws and regulations, as well as company policies, practices and procedures.

We respect internationally recognised Human Rights as established in the Universal Declaration on Human Rights and the International Labour Organisation’s Core Conventions.

In line with the UN Guiding Principles on Business and Human Rights, Inspired recognises the corporate responsibility to respect these principles and demonstrate this through on-going human rights due diligence.

Furthermore, our efforts include ongoing robust engagement with our business and major supply chain partners to mitigate potential human rights impacts beyond our direct control. Our support of internationally recognised Human Rights is consistent with our dedication to enriching our workplace, partnering with our supply chain, preserving the environment and supporting the communities where we operate.

2 Objective

This Human Rights policy exists to:

  1. > Inform employees, business partners and customers of our commitment to human rights.
  2. > Establish our commitment to on-going human rights due diligence.
  3. > Maintain our ethical standards.
  4. > Contribute to the realisation of human rights globally.

3 Scope

Inspired Human Rights Policy applies to all our employees, anyone doing business for or with Inspired and others acting on our behalf.

This applies to all locations where we conduct business and to all company-sponsored events.

4 What are Human Rights?

Human rights are basic rights inherent to all human beings, regardless of nationality, place of residence, sex, sexual orientation, national or ethnic origin, colour, religion, language, or any other status.

5 Policy

Inspired conducts its business in a manner that respects the rights and dignity of all people, complying with all applicable laws and regulations. Our policies reflect our commitment to respecting the protection of internationally recognised Human Rights.

  1. > All employment with Inspired is voluntary. We do not use child or forced labour in any of our operations or facilities. We do not tolerate any form of unacceptable treatment of workers, including but not limited to the exploitation of children, physical punishment or abuse, or involuntary servitude. We fully respect all applicable laws establishing a minimum age for employment, in order to support the effective abolition of child labour worldwide.
  2. > We abide by all laws and regulations regarding pay practices and the classification of employment according to job level and status.
  3. > We respect our employees’ right to choose to join or not join a trade union, or to have recognised employee representation in accordance with local law.
  4. > Diversity is embraced at Inspired. We recognise that a diverse mix of backgrounds, skills and experiences drives new ideas, products, and services and provides us with a sustained competitive advantage.
  5. > We believe everyone should be treated with respect regardless of their background. We are committed to the elimination of discrimination based on gender, race, class, economic status, ethnic background, sexual orientation, age, political beliefs, veteran status, marital status or any other protected class.

We require all suppliers, vendors, contractors, consultants and agents to adhere to our Labour standards and Code of Conduct policies.

6 Compliance

Employees and suppliers are expected to comply with this and all applicable Inspired policies. Violation of this policy or the refusal to cooperate will result in disciplinary action, up to and including termination and referral to the appropriate authorities, where we have sound reason to believe that our partner organisations infringe Human Rights we reserve the right to cease those relationships as warranted. Specific to this policy, employees and suppliers are expected to:

  1. > Never infringe on human rights.
  2. > Be alert to any evidence of human rights infringements in our direct operations or in the operations of our business partners and report any situation in which a human rights infringement is suspected.

7 Human Rights Policy Review

We will review the effectiveness of this policy annually and whenever a change in the law occurs.

Date1st March 2021
Next Review DateAnnually or at point of incident
Approved and Authorised
NameMark Dickinson
PositionChief Executive Officer

Modern Slavery & Human Trafficking Policy

1 Statement

We are committed to ensuring that our business, its direct supply chain and business partnerships are free of modern slavery and human trafficking and will not hesitate to perform due diligence if necessary.

Any evidence or suspicion of the above occurring in any contact organisation or contact individual or group of individuals will immediately result in us submitting a report to the relevant authorities and suspending any interaction between ourselves and the party concerned until a satisfactory outcome has been reached.

We acknowledge our responsibilities in relation to tackling modern slavery and human trafficking and are committed to complying with the provisions of the Modern Slavery Act 2015.

We adhere strictly to the standards required in relation to our responsibilities under all relevant employment legislation.

2 Definition of Modern Slavery

We consider that modern slavery encompasses:

› Human trafficking.
› Forced work through mental or physical threat.
› Being owned or controlled by an employer through mental or physical abuse or the threat of abuse.
› Being dehumanised, treated as a commodity or being bought or sold as property.
› Being physically constrained or having restrictions placed on freedom of movement.

3 Our Intent

We will not enter into a business relationship with any party which knowingly supports or is found to have involved itself in any aspect of the above, nor will we do so ourselves.

4 Our Expectations of Employees & Others

We expect all employees, agents, contractors, subcontractors, consultants, business partners and any other parties (including individuals, partnerships and bodies corporate) associated with us or any of our subsidiaries also to have zero tolerance towards modern slavery. We reserve the right to request access to the policies of all others in this regard.


5 Due Diligence Process

We ensure that modern slavery is not taking place in our organisation by taking the following steps:

The geographical scope of our operations is primarily limited to the UK & Ireland and nature of our work makes modern slavery or human trafficking an unlikely event.
However, we implement the following measures:

› We directly employ our staff.
› We conduct 'right to work diligence'.
› Where we operate outside of these the UK and Ireland and we directly employ our staff we comply with all local laws.
› Where possible we build long-standing relationships with local suppliers and we validate that these entities have suitable anti-slavery and human trafficking policies in place.
› We have a system in place to encourage the reporting of concerns.

6 Measures

The following measures demonstrate our effectiveness in ensuring that modern slavery does not take place in any part of our business:

› Right to work checks completed at recruitment stage and any suspicions by the interview panel regarding modern slavery documented and followed up.
› Ensure minimum employment age is adhered to, in line with relevant legislation.
› Always apply national minimum wage thresholds, in line with the relevant legislation.

7 Reporting Concerns & Reviewing

All of the parties listed in section 4 must report any and all concerns to HR or, in the case of non-employees, their normal point of contact within the Company, or otherwise in accordance with the Company’s Whistleblowing Protection Policy.

Date1st March 2021
Next Review DateAnnually or at point of incident
Approved and Authorised
NameMark Dickinson
PositionChief Executive Officer

GDPR and Privacy Notice

1 Inspired’s Data Privacy Notice

Welcome to an Inspired plc (we, our or us, as applicable) owned and operated website. For further information about us and our contact details, please go to our CONTACT US section below. References in this Privacy Notice to our website refer to all websites operated by the Group and references to services are to services provided to you or the organisation that you represent under a contract with us.

We are committed to respecting your privacy. This Privacy Notice is intended to inform you about how we collect, use and protect any personal data we collect about you when you use our website or services. It sets out how we comply with the data protection laws (the General Data Protection Regulation (UK GDPR) tailored by the Data Protection Act 2018) and what your rights are.

For the purposes of data protection laws, unless otherwise stated in your specific contract of services, we will be the controller of any of your personal data.

We have appointed a data privacy manager who is responsible for the personal data collected and used by us; if you have any questions about this Privacy Notice, please use the details set out within the CONTACT US section below.

This Data Privacy Notice provides details about:

> what personal data we collect

> where we collect your personal data from

> the purpose and legal basis for using personal data provided to us who we share your personal data with

> how long we will keep your personal data

> where we transfer your personal data to

> how we aim to protect your privacy

> your legal rights relating to your personal data

2 What personal data do we collect?

We may collect the following information about you:

> Identity Data including first name, last name, username or similar identifier, title.

> Contact Data including your business email address, business telephone number (including mobile number, business address).

> Details of the correspondence (including e-mail correspondence) you send and receive from us: this includes letters and emails, SMS, MMS and other electronic communication and may in some cases include audio recording of telephone conversations.

> Usage Data – including how you use our website, such as your login time, changes to your account data, user name and password. This is not collected by cookies, but by analysing your usage from the actions you take in connection with our website.

> Marketing and Communications Data including your preferences in receiving marketing from us and your communication preferences.

> Any other personal data you choose to disclose to us.

We also collect, use and share Aggregated Data in connection with your usage, such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

We may use your personal data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.
 

3 Where do we collect your personal data from?

You
We may collect your personal data directly or indirectly from you, for example when you:

> engage with us during the course of our relationship with you or the business you work for including in receipt of services from us;

> use our website including when you complete a web form to ask us to contact you or you sign up to an email alert with us;

> communicate with us regarding our website to ask a question, report a problem or for any other reason; and raise a query, complaint, claim, legal dispute on behalf of yourself or the business you work for.

> We may collect your personal data from the business you work for, for example when they: 

> give us your business email address, so that we can invite you to register to use features on our website or allow us to contact you in order to deliver the contracted services

Other third parties

We may also collect personal data from third parties who have your consent or some other lawful basis for doing so including:

> Companies House;

> social media platforms such as LinkedIn; Instagram, YouTube, Twitter or public Facebook page.


4 How do we use your data?

PurposePersonal Information UsedLawful Basis
To invite you to register to use our websiteIdentity Data, Contact DataPerformance of a contract with the business that you work for
To manage our relationship with you including notifying you of changes to our website or this policyIdentity Data, Contact Data, Marketing and Communications DataYour consent. Performance of a contract with you. Necessary for our legitimate Interests (to keep records updated and to analyse how our customers/users use our website)
To administer and protect our business and our website including troubleshooting, data analysis and system testingIdentity Data, Contact Data, Usage DataNecessary for our legitimate Interests (for running our business, provision of administration and IT services, network security)
To measure and analyse the effectiveness of the advertising we serve youIdentity Data, Contact Data, Usage Data, Marketing and Communications DataConsent Necessary for our legitimate Interests (to develop our products/services and grow our business)
To gather analysis or valuable information and monitor trends so we can improve our websiteIdentity Data, Contact Data, Usage Data, Marketing and Communications DataConsent Necessary for our legitimate Interests (to develop our products/services and grow our business)
Deal with your queries or complaints, claims, legal disputes or raise queries, claims, legal disputes or complaints with you or the business you work forAll the personal information we collectPerformance of a contract with the business that you work for. Necessary for our legitimate interests (to develop our products/services and grow our business). To defend, bring or establish legal claims
Enter into and perform contracts, where we are supplying services to youAll the personal information we collectTo enter into and perform contracts with either yourself or the organisation that you represent.  We have a legitimate to properly perform contracts with third parties


Where you have given us your consent to use your personal data in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the CONTACT US section below. We will generally only process your personal data based on your consent in relation to direct marketing.

Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal data to the extent that we are entitled to do so on a basis other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide marketing information to you.

5 Direct Marketing

To ensure you are kept up to date, we use personal data for marketing purposes and may send you postal mail, texts and/or emails to update you on the latest offers and events. We may also show you online media communications through external social media platforms such as LinkedIn, Instagram, YouTube, Twitter and Facebook, and external digital advertisers such as Google.

You have the right to opt out of receiving marketing communications from us at any time, by:

1. informing us that you wish to change your marketing preferences by contacting our customer support team at [email protected]
2. making use of the simple “unsubscribe” link in emails; and/or
3. contacting our data privacy manager using the details set out within the CONTACT US section below.

This will not stop service messages such as order updates and other non-marketing communications.

6 Who do we share your personal data with?

We may share your personal data with the following third parties:We may employ third party service providers and individuals to facilitate and support our website, provide the web service on our behalf or assist us in analysing how our website is used.

> We use Brighter IR to provide our email alert service if you choose to register for email alerts via our website.

> Other companies within our group and affiliates.

> Purchasers, investors, funders and advisers if we sell or negotiate to sell all or part of our business or assets or restructure our business whether by merger, re-organisation or otherwise.

> Our advisors including legal or other advisors.

> Your advisors including legal or other advisors.

Under certain circumstances we may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court/tribunal or a government agency), regulators, law enforcement agencies, security services, insurers.

These third parties have access to your personal data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

7 How long we keep your personal data for?

We will not retain your personal data for longer than as is necessary for the purposes for which it has been obtained set out in this Privacy Notice and only then for as long as there is any risk of a potential claim, which will be dependent upon the limitation period for the particular type of claim.

Various laws, accounting and regulatory requirements applicable to us also require us to retain certain records for specific amounts of time. In relation to your personal data, we will hold this only for so long as we require that personal information for legal or regulatory reasons or for legitimate organisational purposes. We will not keep your data for longer than is necessary for the purposes for which we collect them.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our website, or we are legally obligated to retain this data for longer periods. We will anonymise your Usage Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this data indefinitely without further notice to you.

Our Data Retention Privacy Notice sets out the length of time we will usually retain personal data and where these default periods might be changed; you can request a copy of our Data Retention Privacy Notice by using the details set out in the CONTACT US section below. We have set out below the main retention periods which will apply: 

> For users, we check accounts annually to see if they are being used. We reserve the right to delete your account and any personal data or other information associated with your use of our website if we identify during an annual review that there is no activity on your account by giving you 180 days prior written notice.

> For marketing contacts it will generally be a period of 2 years after we were last in contact with you.

> For individuals seeking information, making complaints or otherwise corresponding with us it will generally be 2 years.

8 Where do we transfer your personal data to?

Your information, including personal data, may be transferred to, and maintained on computers located outside the United Kingdom and outside the EEA where the data protection laws may differ.

We will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice and no transfer of your personal data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

Please contact us using the details set out in the CONTACT US section set out below if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

9 How do we protect your personal data?

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

Where you have chosen a password that enables you to access services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

Systems are hosted in a secure data centre facility with restricted physical access to the equipment or servers. Data stored within the service is encrypted in accordance with industry standards. Periodic Vulnerability and Penetration testing of our website are undertaken.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

10 What rights do you have under the general data protection regulation?

If you are a resident of the UK under the data protection laws you have certain rights relating to your personal data.

> The right to be informed about how your personal data is being used.

> The right to request access to personal data we hold about you.

> The right to request that we delete your personal data in certain circumstances, for example when the data is no longer necessary for the purposes for which we collected it.

> The right of rectification where the personal data is out-of-date, inaccurate or incomplete.

> The right to object to certain automated decision-making processes using your personal data including profiling.

> The right to restrict processing your personal data.

> The right to data portability; the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format and transferred to another data controller.

> The right to object to processing your personal data and/or to withdraw consent at any time where we relied on your consent to process your personal information.

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. However, some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

Please note that we may request specific information in order to verify your identity before responding to such requests. This is another appropriate security measure to ensure that personal data is not disclosed to any personal who has no right to receive it.

Whilst this Privacy Notice sets out a general summary of your legal rights in respect of personal data, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

If you wish to exercise any of the above rights please use the details provided below within the CONTACT US section.

You as have the right to complain to the Information Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow, SK9 5AF, United Kingdom if you believe we have not handled your personal data in accordance with the law. More information, including contact details, is available at https://ico.org.uk.

11 Links to other sites

Our website may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the privacy notice of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites.

12 Changes to this data privacy notice

We may update our Privacy Notice from time to time. We will notify you of any changes by posting the new Privacy Notice on this page.

We will let you know via email and/or a prominent notice on our website, prior to the change becoming effective and update the date of posting at the bottom of this Privacy Notice.

You are advised to review this Privacy Notice periodically for any changes. Changes to this Privacy Notice are effective when they are posted on this page. 

13 Contact us

Our website is operated by, and/or services are provided by, Inspired Energy Solutions Ltd. We are registered in England and Wales under company number 04005541 and ICO Registration Z4999309 and have our registered office at 29 Progress Park Orders Lane, Kirkham, Preston, England, PR4 2TZ.

To contact us, please email [email protected] or telephone +44 (0)1722 689249

Date1st March 2021
Next Review DateAnnually or at point of incident
Approved and Authorised
NameMark Dickinson
PositionChief Executive Officer

Recognition of ILO Conventions Policy

1 Statement

The ILO (International Labour Organisation) brings together governments, employers and workers of 187 member States, to set labour standards, develop policies and devise programmes promoting decent work for all women and men.

We recognise and undertake to create our policies and principles in accordance with the ILO Conventions set out below:

  1. Freedom of Association and Protection of the Right to Organise Convention, 1948 (No. 87)
  2. Right to Organise and Collective Bargaining Convention, 1949 (No. 98)
  3. Forced Labour Convention, 1930 (No. 29)  (and its 2014 Protocol )
  4. Abolition of Forced Labour Convention, 1957 (No. 105)
  5. Minimum Age Convention, 1973 (No. 138)
  6. Worst Forms of Child Labour Convention, 1999 (No. 182)
  7. Equal Remuneration Convention, 1951 (No. 100)
  8. Discrimination (Employment and Occupation) Convention, 1958 (No. 111)
Date1st March 2021
Next Review DateAnnually or at point of incident
Approved and Authorised
NameMark Dickinson
PositionChief Executive Officer

Supplier Code of Conduct

1 Statement

The relationship between Inspired and our suppliers is primarily governed by the contract properly agreed between us and the laws of the land which has jurisdiction over such agreement.

Without prejudice to such agreements our Code of Conduct sets out what we value as a company. These principles define who we are, how we work, and what we stand for. They also tell us what we expect of ourselves and all who work with us.

The Code of Conduct is not a set of rules and it cannot cover every possible situation. We are all required to use our best judgment in applying the principles of the Code and to demonstrate its spirit in everything that we do.

We appreciate that many of you who work with us have developed your own principles to guide you in the workplace, so we don’t ask you to replace those with ours. However, we do ask that you respect our Code and understand that we have made a fundamental commitment to work only with those whose standards are consistent with our own.

2 Our Code

We expect our suppliers to work to a standard which is equivalent to and at least as high as the standard that we ourselves operate to. As such all suppliers are asked to comply with the following policies as published on our website:

a) Anti-bribery & Corruption
b) Anti-discrimination,
c) Board gender diversity,
d) Climate change and the environment
e) Data Privacy Notice
f) Employee gender diversity & Equal Pay
g) Equal Opportunities and Diversity
h) Grievance/complaints handling
i) Health & Safety and Accident Prevention
j) Human rights,
k) Modern Slavery and Human Trafficking
l) Recognition of ILO Conventions,
m) Supplier code of conduct,
n) Whistleblower protection,

3 Raising a Concern

Generally, you should first discuss the matter with senior management within your organisation, who in turn should feel confident to raise it with our senior management.

If you believe the matter cannot be handled appropriately in this way, you can contact our executive management directly.

4 Supplier Code of Conduct Review

We will review the effectiveness of this policy annually and whenever a change in the law occurs.

Date1st March 2021
Next Review DateAnnually or at point of incident
Approved and Authorised
NameMark Dickinson
PositionChief Executive Officer

Whistleblower Protection Policy

1 What is a Whistleblower?

You’re a whistle-blower if you’re a worker (employees, contractors, consultants, officers, interns, casual and agency workers) and you report certain types of wrongdoing. This will usually be something you’ve seen at work - though not always.

The wrongdoing you disclose must be in the public interest. This means it must affect others, for example the general-public.

Personal grievances that you may have (for example bullying, harassment, discrimination) are not covered by whistleblowing law, unless your particular case is in the public interest (we recommend you seek independent advice if you believe your case is in the public interest). For personal grievances you should use the company HR process.

We are committed to operating at all times, and in everything that we do, to the highest standards of integrity. However, should you become aware of such wrongdoing, you can raise your concern at any time about an incident that happened in the past, is happening now, or you believe will happen in the near future.

Please follow the procedure outlined in this policy to immediately report any concerns that you have about this kind of conduct, so that we can take the necessary action to address these concerns as fast as possible.

As a whistleblower you’re protected by law - you should not be treated unfairly or lose your job because you ‘blow the whistle’.

2 Wrongdoing that counts as Whistleblowing

You’re protected by law if you report any of the following:

  1. > a criminal offence, for example fraud.
  2. > someone’s health and safety is in danger.
  3. > risk or actual damage to the environment.
  4. > a miscarriage of justice.
  5. > the company is breaking the law, for example does not have the right insurance.
  6. > you believe someone is covering up wrongdoing.

The following complaints do not count as whistleblowing.

  1. > Personal grievances (for example bullying, harassment, discrimination) are not covered by whistleblowing law, unless your particular case is in the public interest.

Report these under your employer’s grievance policy) for help and advice on resolving a workplace dispute.

Wrongdoing does not just cover the actions of the company but also covers the actions of third parties such as suppliers, service providers, and clients, as well as our staff.

If you are concerned about a third party, please also raise them with us in accordance with section 6.

3 Who is protected by law?

You’re protected if you’re a worker, for example you’re:

  1. > an employee, such as a police officer, NHS employee, office worker, factory worker
  2. > a trainee, such as a student nurse
  3. > an agency worker
  4. > a member of a Limited Liability Partnership (LLP)

You should seek independent advice if you’re not sure you’re protected, for example from Citizens’ Advice.

A confidentiality clause or ‘gagging clause’ in a settlement agreement is not valid if you’re a whistleblower.

4 How do 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 or wrongdoing.

However, to qualify for protection, the disclosure must, in the reasonable belief of the worker making the disclosure, show that one of forms wrongdoing set out in section 2 has occurred.

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 the designated persons set out in section 6 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 whistleblower 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. The consequences of us taking this action could include dismissal of such individual(s) for gross misconduct. Whistleblowers may also be entitled to take personal legal action against those individuals.

If you would like more information about your rights as a whistleblower and how you are entitled to be protected, you can the employee assistance program (EAP).

5 Confidentiality and anonymity

You are always encouraged to raise concerns openly, and we actively discourage anonymous whistleblowing. This is because it is not always easy to manage and to investigate anonymous reports, especially since if we are unable to ask you for clarification for further details, we may struggle to clarify and find evidence to investigate your concerns and 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 reprisal as set out in section 4.

6 Who should I ‘blow the whistle’ to?

When you report concerns because you have a reasonable belief of wrongdoing to others which is in the public interest (as describe in section 2) you should report them to the designated persons set out below:

  1. > In the first instance you should report any concern HR or your line manager.
  2. > If the matter concerns HR or your line manager then you should report the matter to the CEO or CFO.
  3. > If the matter concerns the CEO or CFO you should write to the Board of Directors.

If you would like independent support with respect to Whistleblowing you should use the EAP or contact Citizens Advice

7 Whistleblowing to others outside Inspired PLC?

Our policy covers the process for raising, investigating, and resolving wrongdoing within [name of business]’s workplace.

The whistleblowing procedure 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 [name of business] as part of this process.

However, we recognise that potentially, in exceptional circumstances, you might wish to involve an external body such as 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.

We do not recommend involving the media in a whistleblowing matter as this 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.

As with every other matter relating to your employment, your duty of confidentiality and trust to your employer still exist and we would generally expect you to have taken all reasonable steps to deal with a whistle blowing matter internally, or with an external regulator and to have taken full advice from a lawyer or from Public Concern At Work, before you could justify involving the press.

We will treat any contact with the press as a serious disciplinary issue justifying dismissal unless such action has been taken on advisement.

8 What process should I follow?

Please follow this procedure:

  1. > Raise your concerns with appropriate person, as set out in section 6, in the first instance. You may do so in writing or in person.
  2. > Please explain that you are raising your concerns as part of the Inspired Energy PLC whistleblowing policy and procedure. Then set out all the key facts, including names of those involved and all relevant dates.
  3. > 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.
  4. > 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 following investigation that we conduct in relation to the concerns raised by you.
  5. > 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 relevant external (or internal) specialists to help us conduct a thorough, fair and responsible investigation.
  6. > 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.
  7. > 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 the next level of escalation as set out in section 6.

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, should a worker raise a false concern with us in bad faith (e.g. for malicious reasons), we will invoke our disciplinary policy and you may be subject to disciplinary action.

9 Whistleblowing Policy Review

This policy does not form part of your employment contract. We will review the effectiveness of this policy annually and whenever a change in the law occurs.

Date1st March 2021
Next Review DateAnnually or at point of incident
Approved and Authorised
NameMark Dickinson
PositionChief Executive Officer