The Company = NC Associates

1. The Company is committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses.
2. The Company is committed to ensuring that its staff and any workers it supplies (directly or indirectly) are not subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and similar human rights abuses.
3. The Company provides appropriate training and awareness information for all of its staff. In particular, our leadership team receive detailed training in identifying and resolving concerns around modern slavery and human trafficking.
4. Our recruiters, HR personnel, and/or staff involved in our procurement and supply chains undertake training courses that include guidance around modern slavery and human trafficking, as well as other wider human rights issues.
5. All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management.
6. Any staff, workers or other parties are strongly encouraged to report any concerns or suspicions that they might have to our Group’s legal team.
7. Reports surrounding these issues are taken extremely seriously by our board of directors who are committed to ensuring that all investigations shall be prompt and effective. If our investigations reveal any issues, we are committed to taking appropriate action, including but not limited to:
   • Working with the appropriate organisations to improve standards,
   • Removing that organisation from our preferred supplier list,
   • Passing details to appropriate law enforcement bodies.
8. We regularly monitor our risks in this area through the use of relevant key performance indicators, including:
   • The percentage of suppliers who sign up to an appropriate code or provide their own modern slavery statements,
   • The amount of time spent on audits, re-audits, spot checks, and related due diligence, and
   • The level of modern slavery training and awareness amongst our staff.
9. As part of our efforts in this area, we publish and update a modern slavery statement on an annual basis.
10. We would also recommend reading this in conjunction with our other policies.

This policy was adopted on January 2018 after being agreed by our board of directors. It is reviewed annually.

The company = NC Associates

Our Corporate Social Responsibility (CSR) company policy outlines our efforts to be socially responsible, supporting the (local) communities in which we operate, and providing employees with opportunities for charitable work.

Our company’s social responsibility falls under two categories: compliance and proactiveness. Compliance refers to our company’s commitment to legality and willingness to observe community values. Proactiveness is every initiative to promote human rights, help communities and protect our natural environment.

Compliance

Legality

Our company will:

• Respect the law
• Honour its internal policies
• Ensure that all its business operations are legitimate
• Keep every partnership and collaboration open and transparent
• Business ethics

We’ll always conduct business with integrity and respect to human rights. We’ll promote:

• Safety and fair dealing
• Respect
• Anti-bribery and anti-corruption practices

Protecting the environment

Our company recognises the need to protect the natural environment. Keeping our environment clean and unpolluted is a benefit to all. We’ll always follow best practices when disposing garbage and using chemical substances. Stewardship will also play an important role.

Protecting people

We’ll ensure that we:

• Don’t risk the health and safety of our employees and community.
• Support diversity and inclusion.
• Human rights

Our company is dedicated to protecting human rights. We are a committed equal opportunity employer and will abide by all fair labour practices. We’ll ensure that our activities do not directly or indirectly violate human rights in any country (e.g. forced labour).

Proactiveness

Donations and aid

Our company may preserve a budget to make monetary donations. These donations will aim to:

Advance the arts, education and community events and alleviate those in need.

Volunteering

Our company will encourage its employees to volunteer. They can volunteer through programs organised internally or externally. Our company may sponsor volunteering events from other organisations.

Preserving the environment

Apart from legal obligations, our company will proactively protect the environment. Examples of relevant activities include:

• Recycling
• Conserving energy
• Organising reforestation excursions
• Using environmentally-friendly technologies
• Supporting the community

Our company may initiate and support community investment and educational programs. For example, it may begin partnerships with vendors for constructing public buildings. It can provide support to non-profit organisations or movements to promote cultural and economic development of global and local communities.

Learning

We will actively invest in R&D. We will be open to suggestions and listen carefully to ideas. Our company will try to continuously improve the way it operates.

The Company maintains a commitment to monitor best practice and operate continuous improvement in our CSR policy.

All our team have the opportunity to involve themselves in their charitable passions.

Team members are regularly released from work in order to support their chosen charitable activities including bereavement counselling and school governor meetings.

Our CSR is ingrained throughout our organisation.

1. Policy

Any reference to “we”, “us” means NC Associates. This Policy represents the retention and disposal of records and the retention and disposal of electronic documents.

2. Purpose

The purpose of this Policy is to ensure that necessary records and documents of NC Associates are adequately protected and maintained, and to ensure that records that are no longer needed by NC Associates or are of no value are discarded at the proper time. This Policy is also for the purpose of aiding employees of NC Associates in understanding their obligations in retaining electronic documents – including e-mail, Web files, text files, sound and video files, PDF documents, and all Microsoft Office or other formatted files.

3. Administration

Attached as Appendix A is a Record Retention Schedule that is approved as the initial maintenance, retention and disposal schedule for physical records of NC Associates and the retention and disposal of electronic documents. We will make modifications to the Record Retention Schedule from time to time to ensure that it follows National legislation and includes the appropriate document and record categories for NC Associates; monitor legislation affecting record retention; annually review the record retention and disposal program; and monitor compliance with this Policy.

In addition, any retained information can only be used for the purpose for which it is stored. This is compliant with the Data Protection Act 1998 and the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679)

4. Suspension of Record Disposal in Event of Legal Proceedings or Claims

There are certain occasions when information needs to be preserved beyond any limits set out in the Policy. The Policy must be SUSPENDED relating to a specific customer or document and the information retained beyond the period specified in the NC Associates Data Retention Schedule in the following circumstances:

Legal proceedings or a regulatory or similar investigation or obligation to produce information are known to be likely, threatened or actual.

A crime is suspected or detected.

Information is relevant to a company in liquidation or receivership, where a debt is due to NC Associates.

The owning unit considers information to be of potential historical importance, and this has been confirmed by the Administrator.

In the case of possible or actual legal proceedings, investigations or crimes occurring, the type of information that needs to be retained relates to any that will help or harm NC Associates or the other side’s case or liability or amount involved.

If there is any doubt over whether legal proceedings, an investigation or a crime could occur, or what information is relevant or material in these circumstances, the Administrator should be contacted, and legal advice sought.

The Administrator shall take such steps as is necessary to promptly inform all staff of any suspension in the further disposal of documents.

5. Security of personal information

NC Associates will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

NC Associates will store all personal information on our secure (password- and firewall-protected) servers.

The Client should acknowledge that the transmission of information over the internet is inherently insecure, and that NC Associates cannot guarantee the security of data sent over the internet.

The Client will be responsible for keeping their Username and Password used for accessing the NC Associates website confidential; NC Associates will not ask for password other than when needed to log in to our website.

6. Amendments

NC Associates may update this policy from time to time by publishing an updated version. This page should be checked occasionally to ensure that the policy remains relevant.

7. Applicability

This Policy applies to all physical records generated during NC Associates’ operation, including both original documents and reproductions. It also applies to the electronic documents described above.

This Policy was approved by the Board of Directors of NC Associates on 11^th July 2022.

APPENDIX A RECORD RETENTION SCHEDULE

The Record Retention Schedule is organised as follows:

SECTION TOPIC

1. Accounting and Finance
2. Contracts
3. Corporate Records
4. Correspondence and Internal Memoranda
5. Personal Information
6. Electronic Records
7. Grant Records
8. Insurance Records
9. Legal
10. Miscellaneous
11. Personnel Records
12. Tax Records

1. ACCOUNTING AND FINANCE

Record Type and then Retention Period

Annual Audit Reports and Financial Statements: Permanent
Annual Audit Records, including work papers and other documents that relate to the audit: 7 years after completion of audit
Annual Plans and Budgets: 7 years
Bank Statements and Cancelled Cheques: 7 years
Employee Expense Reports: 7 years
Interim Financial Statements: 7 years

1. CONTRACTS

Record Type and then Retention Period

Contracts and Related Correspondence (including any proposal that resulted in the contract and all other supportive documentation): 7 years after expiration or termination

1. CORPORATE RECORDS

Record Type and then Retention Period

Corporate Records (minutes, signed minutes of the Board and all committees, record of incorporation, articles of incorporation, annual corporate reports): Permanent

Licenses and Permits: Permanent

1. CORRESPONDENCE AND INTERNAL MEMORANDA

General Principle: Most correspondence and internal memoranda should be retained for the same period as the document to which they pertain or support. For instance, a letter pertaining to a particular contract would be retained as long as the contract (7 years after expiration). It is recommended that records that support a particular project be kept with the project and take on the retention time of that particular project file.

Correspondence or memoranda that do not pertain to documents having a prescribed retention period should be discarded sooner. These may be divided into two broad categories:

1. Those pertaining to routine matters and having no significant, lasting consequences should be discarded within five years. Some examples include:

Routine letters and notes that require no acknowledgment or follow up, such as notes of appreciation, congratulations, letters of transmittal, and plans for meetings.
Form letters that require no follow up.

Letters of general inquiry and replies that complete a cycle of correspondence.

Letters or complaints requesting specific action that have no further value after changes are made or action taken (such as name or address change).
Other letters of inconsequential subject matter or that definitely close correspondence to which no further reference will be necessary.

2. Those pertaining to non-routine matters or having significant lasting consequences should be retained permanently.
3. Retaining personal information
4. This Section sets out the data retention policies and procedure of NC Associates, which are designed to help ensure compliance with legal obligations in relation to the retention and deletion of personal information
5. Personal information that is processed by NC Associates for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

Without prejudice to point 2 (above) NC Associates will usually delete personal data falling within the categories set out below at the date/time set out below:

Record Type and then Retention Period

• Information about a computer and about visits to and use of this website (including an IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths: 2 years
• Information provided when registering with our website (including email address): 2 years
• Information provided when completing a profile on our website (including a name, gender, date of birth, interests and hobbies, educational details): 2 years
• Information provided for subscribing to email notifications and/or newsletters (including a name and email address): Indefinitely or until the client chooses to ‘unsubscribe’
• Information provided when using the services on the website, or that is generated during the use of those services (including the timing, frequency and pattern of service use): Indefinitely
• Information relating to any subscriptions made (including name, address, telephone number, email address and sector sought): 2 years or until consent is withdrawn
• Information posted to our website for publication on the internet: 5 years after post
• Information contained in or relating to any communications sent through the website (including the communication content and meta data associated with the communication): 2 years following contact
• Any other personal information chosen to be sent: 2 years following contact

Notwithstanding the other provisions of this Section, NC Associates will retain documents (including electronic documents) containing personal data:

(a) to the extent that NC Associates is required to do so by law;

(b) if NC Associates believes that the documents may be relevant to any ongoing or prospective legal proceedings;

(c) and to establish, exercise or defend NC Associates’ legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

(d) if explicit consent is given by the data subject. Consent is requested at least every 2 years from candidates seeking contract roles and at least every 12 months for candidates seeking permanent employment.

All NC Associates data and systems are backed up daily, connected to a Tier 1 data centre.

1. ELECTRONIC DOCUMENTS
2. Electronic Mail: Not all email needs to be retained, depending on the subject matter. Electronic documents that do not fall within a category with a longer retention period should be treated as set out below:

All e-mail—from internal or external sources – is to be archived after 12 months.
Staff will take care not to send confidential/proprietary NC Associates information to outside sources.
Staff will strive to keep all but an insignificant minority of their e-mail related to business issues.
Any e-mail staff deems vital to the performance of their job should be copied to the relevant client or candidate record in their CRM system.

2. Electronic Documents: including Office 365 and PDF files, retention also depends on the subject matter.

NC Associates does not automatically archive electronic files beyond the dates specified in this Policy. It is the responsibility of all staff to adhere to the guidelines specified in this policy.

In certain case’s a document will be maintained in both paper and electronic form. In such cases the official document will be the electronic document.

1. INSURANCE RECORDS

Record Type and then Retention Period

Certificates Issued to NC Associates Permanent
Claims Files (including correspondence, medical records, etc.) Permanent
Insurance Policies (including expired policies) Permanent

1. LEGAL FILES AND PAPERS

Record Type and then Retention Period
Documentation relating to actual or potential civil litigation:

• Legal Memoranda and Opinions (including all subject matter files): 7 years after close of matter
• Litigation Files (including documents and internal memoranda): 1 year after expiration of appeals or time for filing appeals
• Court Orders: 7 years from the date of the order
• Settlement agreements: 7 years from the date of the agreement

Documentation relating to actual or potential litigation in the Employment Tribunal:

• Legal Memoranda and Opinions (including all subject matter files): 2 years after close of matter
• Employment Tribunal Files (including documents and internal memoranda): 1 year after the expiry of the time limit to bring a claim or the conclusion of the matter.
• Tribunal Orders: 7 years from the date of the order
• Settlement agreements: 7 years from the date of the agreement

1. MISCELLANEOUS

Record Type and then Retention Period

Material of Historical Value (including pictures, publications): Permanent
Policy and Procedures Manuals – Original: Permanent Annual Reports: Permanent

1. PERSONNEL RECORDS

Record Type and then Retention Period

Employee Personnel Records (including individual attendance records, application forms, job or status change records, performance evaluations, termination papers, withholding information, garnishments): 2 years after termination of employment
Employment Contracts – Individual: 7 years after separation

1. TAX RECORDS

General Principle: NC Associates must keep books of account or records as are sufficient to establish amount of gross income, deductions, credits, or other matters required to be shown in any such return.

These documents and records shall be kept for as long as the contents thereof may become material in the administration of state, and local income, franchise, and property tax laws.

Record Type and then Retention Period

• Tax-Exemption Documents and Related Correspondence: Permanent
• Tax Bills, Receipts, Statements: 7 years
• Tax Returns: Permanent
• Sales/Use Tax Records: 7 years
• Annual Information Returns: Permanent

The Company = NC Associates

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

The Company is committed to diversity and will promote diversity for all employees, workers and applicants. We will continuously review all aspects of recruitment to avoid unlawful discrimination. The Company will treat everyone equally and will not discriminate on the grounds of an individual’s “protected characteristic” under the Equality Act 2010 (the Act) which are age, disability, gender re-assignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation. We will not discriminate on the grounds of an individual’s membership or non-membership of a Trade Union. All staff have an obligation to respect and comply with this policy.

The Company is committed to providing training for its entire staff in equal opportunities and diversity.

The Company will avoid stipulating unnecessary requirements which will exclude a higher proportion of a particular group of people and will not prescribe discriminatory requirements for a role.

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

DISCRIMINATION

Under the Act unlawful discrimination occurs in the following circumstances:

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

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

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

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

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

Where there is an occupational requirement then the client must show that applying the requirement is a proportionate means of achieving a legitimate aim, i.e. the employer must be able to objectively justify applying the requirement. An occupational requirement does not allow an employer to employ someone on less favourable terms or to subject a person to any other detriment.

Neither does an occupational requirement provide an excuse against harassment or victimisation of someone who does not have the occupational requirement.

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

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

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

The Company will use best endeavours to comply with the Act and will not accept instructions from clients that will result in unlawful discrimination.

Harassment
Under the Act, harassment is defined as unwanted conduct that relates to a protected characteristic which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual. This includes unwanted conduct of a sexual nature.

The Company is committed to providing a work environment free from unlawful harassment.

The Company will ensure that the consultants do not harass any individual.

Examples of prohibited harassment are:

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

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

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

The Company will undertake a thorough investigation of the allegations. If it is concluded that harassment has occurred, remedial action will be taken.

All employees and workers will be expected to comply with The Company’s policy on harassment in the workplace. Any breach of such a policy will lead to the appropriate disciplinary action.
Any individual who The Company finds to be responsible for harassment will be subject to the disciplinary procedure and the sanction may include termination.

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

The Company will ensure that the consultants do not victimise any individual.

DISABLED PERSONS

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

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

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

Reasonable adjustments in recruiting could include:

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

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

The Company will not discriminate against a disabled person:

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

The Company will make career opportunities available to all people with disabilities and every practical effort will be made to provide for the needs of staff, candidates and clients.

AGE DISCRIMINATION

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

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

Age group can have various references:

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

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

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

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

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

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

GENDER REASSIGNMENT POLICY
The Company recognises that any employee or worker may wish to change their gender during the course of their employment with the Company.

The Company will support any employee or worker through the reassignment.

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

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

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

RECRUITMENT OF EX-OFFENDERS

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

COMPLAINTS AND MONITORING PROCEDURES
The Company has in place procedures for monitoring compliance with this policy and for dealing with complaints of discrimination. These will be made available immediately upon request. Any discrimination complaint will be investigated fully.

The Company = NC Associates

It is an important duty of The Company, in the conduct of its business operations, to ensure a safe and healthy working environment for all its employees. The organisation accepts the fact that this implies a corresponding duty of ensuring that necessary organisation, equipment, and instruction is provided to fulfil this obligation. An effective health and safety policy requires the full collaboration and co-operation of all employees; everybody is asked to read this policy and accept their own personal responsibility for health and safety at work. The objectives of this policy are fundamental to our business and the Company Directors are responsible for ensuring that the requirements of this policy are achieved.

The Company is committed to operating the business in accordance with the Health and Safety at Work Act 1974 and all applicable regulations made under the Act, as far as reasonably practicable.

• Risk assessments are to be completed by the brand manager/director to assess the office environment to ensure our workplaces are safe for our workers. Completed risk assessments are sent to the Group’s head office for central collation and record keeping.

• Provide and maintain facilities, equipment, and systems of work that are safe and without risks to health.

• Provide such information, instruction supervision as is necessary to ensure the health and safety at work of employees and visitors.

• Maintain any place of work under the Company’s control in a condition that is safe and without risks to health and to provide and maintain means of access to and egress from it that are safe and without such risks.

• Provide and maintain a working environment for employees that is safe and without risks to health and is adequate as regards facilities and arrangements for their welfare at work.

• Encourage staff to set exacting standards of health and safety by personal example and to instill an attitude of mind which accepts good health and safety practice as normal.

• Monitor the effectiveness of health and safety provisions within The Company.

• Keep the Health & Safety Policy under regular review and to duly publish any amendments.

Management and staff have responsibility for implementing the specific arrangements made under this policy throughout the Company. All employees are expected to familiarise themselves with its provisions and fulfill their defined responsibilities, a copy of all related policies will be held in the HR department and will be made available to all employees.

This policy will be audited for its effectiveness on a regular basis. H&SPolicy/AuthorisingDeptHR/Ver1.2/Feb24

Health & Safety Statement from the CEO

The Company regards the management of health and safety as an integral part of its business and as a management priority. It is our policy that all activities and work will be conducted in a safe manner, and we will ensure the health, safety and welfare of our employees and others who may be affected by our activities.

Proper management of health and safety issues is seen as an integral part of the efficient management of the Company’s activities, and critical to developing the professional culture of the Company and establishing and maintaining a solid reputation with all our customers.

The Company is committed to ensure the health, safety & wellbeing of all staff in line with government guidance and legislation.

Organisation

Ultimate responsibility for Health & Safety rests with The Company and its team of directors. The HR Director has specific responsibility for overseeing the implementation of Health & Safety policy and for advising and updating the Board of The Company and CEO on developments and performance.

All employees, contractors and sub-contractors are required to cooperate with the Company and their colleagues in implementing the policy and shall ensure that their own work is without risks to themselves and others as far as reasonably practicable. And to be proactive on health and safety issues as part of the continued development of the health and safety culture of the organisation

Directors

The Company’s directors have responsibility for implementation of the Health & Safety Principles and Policy in their areas of responsibility. They must show leadership by ensuring the organisation, management and conduct of operations is in line with The Company standards and ensuring this is supported by adequate resource allocation to implement this policy across the business.

All employees have the responsibility to co-operate with the directors and management to achieve a healthy and safe workplace and to take reasonable care of themselves and others.

Whenever an employee notices a health or safety problem which they are not able to put right, they must straightaway inform a member of the Health & Safety Committee.

Managers

Managers have responsibility for the health, safety and wellbeing of those working within their area of operation and those who may be affected by the activities. They must ensure that adequate systems are in place to ensure delivery of policy and standards and meet local statutory requirements. H&SPolicy/AuthorisingDeptHR/Ver1.2/Feb24

Those tasked with the supervision of staff, at whatever level, are required to give careful attention to the health and safety of those under their supervision and to ensure that appropriate precautions are taken.

To fulfil its function, the degree of supervision must have reasonable regard to the level of training, experience and expertise of employees being supervised.

The responsibilities of manager(s) within the company shall be:

• To read and understand the company’s safety policy and to ensure that its provisions are being effectively conducted.

• To bring the provisions of this policy, as far as they affect the personnel, to the attention of the employees under the control of managers/supervisors.

• To inspect machinery, equipment and structures regularly and to ensure that any defects discovered are remedied forthwith.

• To prevent access by the workforce or other persons to any defective equipment or structures until the faults have been rectified.

• To ensure that employees are adequately instructed in the safe operation of equipment and machinery.

• To ensure that any areas of the site to which the public or visitors may have access, are maintained to ensure their safety.

• To arrange for all necessary insurances, certificates etc., appropriate to the site’s size and function.

• To arrange via the responsible person for the reporting of all incidents to the insurers where appropriate.

• To arrange the appropriate fire-certificates for each site, the proper maintenance of firefighting equipment, regular fire drills and adequate access to fire-fighting services.

• Ensure that adequate first-aid facilities are available and adequately maintained.

• To ensure that all accidents are reported in accordance with the provision of this policy.

• Ensure that no unnecessary risks are taken by the employees in pursuance of their duties and to ensure a site disciplinary procedure is in place for offenders.

• Set a personal example.

• To give advice upon this policy when requested by either the directors or workforce.

Individuals

Individual employees have a duty to conduct their work in a safe manner to prevent injury and ill health either to themselves or to others who may be affected by their acts or omissions at work.

Individuals are required to comply with the Company’s Health and Safety Policy as it relates to their work activities, and to any action to be taken in case of an emergency.

Amendments

Any amendments will be notified by revision of this document.

Policy Statement

This policy is approved by the Bluestones Investment Group Limited Board and is reviewed annually.

The policy applies to Bluestones Investment Group Limited and its subsidiary companies (except subsidiary companies that have published a separate modern slavery related policy on their website).

References to the Group relate to Bluestones Investment Group Limited and its subsidiary companies.  References to ‘we’, ‘us’ ‘our’ etc are intended to relate to each company within the Group to which this policy applies. 

This policy applies to all persons working with us or on our behalf in any capacity, including employees at all levels, directors, officers, consultants, agency workers, contractors and suppliers.

This policy does not form part of any employee’s contract of employment, and we may amend it at any time.

Responsibilities

You must ensure that you read, understand and comply with this policy.

The Managing Director of each company within the Group has overall responsibility for ensuring that their company and those working for or on behalf of their company complies with this policy. 

If you suspect a breach you must notify your manager, Board Sponsor or the Bluestones Group Head of Legal as soon as possible.  Concerns about any issue or suspicions of modern slavery in our business or supply chains should be raised at the earliest possible stage. Concerns may also be reported in accordance with our Whistleblowing Policy.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should promptly inform the HR Department ([email protected]). You may also raise concerns in accordance with our Grievance Policy.

Commitments

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

We are committed to conducting our business dealings and relationships in a way that safeguards against modern slavery and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains. 

The systems and controls used in relevant business dealings and relationships include due diligence processes, due diligence questionnaires, compliance audits, the use of specific contractual provisions with third parties relating to compliance with this policy and the Modern Slavery Act 2015 and regular monitoring. The appropriate systems and controls will be determined in line with our commitment in this Policy.

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us and on our behalf.  Individuals and companies must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.

We have a zero-tolerance approach to modern slavery in our organisation and supply chains. 

We expect the same high standards from all of our contractors, suppliers and other business partners and we expect that our suppliers will hold their own suppliers to the same high standards.

We are committed to providing awareness information and training around modern slavery to all individuals who work for us.

Breaches of this Policy

Alleged breaches of this policy will be taken seriously, and we commit to investigating such matters at an appropriate level of seniority in an effective and expeditious manner.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. 

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

NC Associates is committed to protecting and respecting your privacy.

Any references to “we”, “us”, “our” means NC Associates as defined in section 1159 of the UK Companies Act 2006.

This notice together with our Data Retention Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

The UK General Data Protection Regulation (UK GDPR) (Regulation (EU) 2016/679) has been directly incorporated into UK law sitting alongside the Data Protection Act 2018 (“DPA”) and aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.

We will comply with UK GDPR and the DPA which means your data will be:

• Used lawfully, fairly and in a transparent way;
• Collected only for valid purposes that we have clearly explained to you and not used in a way which is incompatible with those purposes;
• Relevant to the purposes we have told you about and limited to only those purposes;
• Accurate and kept up to date;
• Kept only as long as necessary for the purposes we have told you about;
• Kept securely.

Please read the following carefully to understand more detail our views and practices regarding your personal data and how we will treat it.

For the purposes of data protection legislation in force from time to time our nominated representative is NC Associates Managing Director.

Who we are and what we do

NC Associates is a professional services recruitment company who specialise in recruiting roles in Accountancy and Finance, Business Support, Engineering, Legal, Sales and Marketing, and Technology. We are a subsidiary company of Bluestones Investment Group Limited who is an investment company in the recruitment industry. We collect the personal data of the following types of people to allow us to undertake our business;

• Prospective and placed candidates for permanent or temporary roles;
• Prospective and live client contacts;
• Supplier contacts to support our services;
• Employees, consultants, temporary workers;

We collect information about you to carry out our core business and activities.

Information you give to us, or we collect about you

This is information about you that you give us by filling in forms on our site ncassociates.co.uk (our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site.

The information you give us, or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.

You may also give us, or we may collect or store more sensitive personal data such as information about your race, ethnicity, religious beliefs, sexual orientation, political opinions, health (including any medical condition, health and sickness records) or information about criminal convictions or offences.

Information we collect about you when you visit our website

With regard to each of your visits to our site we will automatically collect the following information:

technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version.

information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

Information we obtain from other sources

This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, personal recommendations. In this case we will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.

We are working closely with third parties including companies within our Group, business partners, sub- contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies and professional advisors. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.

Purposes of the processing and the legal basis for the processing

We use information held about you in the following ways:

To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us, or we think will be of interest to you because it is relevant to your career or to your organisation.

To provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with, or enquired about.

The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.

Our legal basis for the processing of personal data is our legitimate interests, described in more detail below, although we will also rely on contractual obligations to which you are subject, legal obligations and consent for specific uses of data.

We will rely on contractual obligations if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.

We will rely on legal obligation in some cases, where we are required by law or regulation to process your data.

We will in some circumstances rely on consent for particular uses of your data. Where we rely on consent, you will be asked for your express consent. An example of when we will rely on consent as the legal basis for processing your data is when we process your data for marketing purposes.

Our Legitimate Interests

Our legitimate interests in collecting and retaining your personal data is described below:

As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contact details is a fundamental part of this process.

In order to support our candidates’ career aspirations and our clients’ resourcing needs, we require a database of candidate and client personal data. The database will contain historical information as well as current resourcing requirements.

To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts.

Consent

Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.

Other Uses we will make of your data:

We will also use your data:

• To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• To improve our site to ensure that content is presented in the most effective manner for you when you are using your computer or other devices;
• To notify you about changes to our service;
• To allow you to participate in interactive features of our service, when you choose to do so;
• As part of our efforts to keep our site safe and secure;
• To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

We do not undertake automated decision making or profiling. We use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process.

Do you have to provide us with personal data?

You may refuse to give us your personal and sensitive personal data. Furthermore, you have the right to ask us to delete, change or stop processing your data that we have already received or collected. If you do not provide us with personal or sensitive personal data, or if you request a restriction of processing however, we may not be able to provide you with the services that you have requested and that are stated in this policy.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

Call Recording Policy

Please be advised that telephone calls to and from our business may be recorded for training, monitoring, quality assurance and transcription purposes. The transcription is to capture call summary and actions.

Disclosure of your information inside and outside of the UK and the EEA

We will share your personal information with:
Any member of our group both in the UK, the EEA and outside of the EEA. Selected third parties including:

• Clients for the purpose of introducing candidates to them;
• Candidates for the purpose of arranging interviews and engagements;
• Clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
• subcontractors including email marketing specialists, event organisers, payment and other financial service providers
• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
• Analytics and search engine providers that assist us in the improvement and optimisation of our site;
• Credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.
• Third party IT providers and Group companies involved in the provision of support to the company they contract with.

We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If a relevant Group company or all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of relevant Group company our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

The lawful basis for the third-party processing will include:

• Their own legitimate interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
• Satisfaction of their contractual obligations to us as our data processor;
• For the purpose of a contract in place or in contemplation;
• To fulfil their legal obligations.

Where we store and process your personal data

The data that we collect from you may/will be transferred to, and stored at, a destination outside the UK or European Economic Area (”EEA”). It may be transferred to third parties outside of the UK or the EEA for the purpose of our recruitment services. It may/will also be processed by staff operating outside the UK or the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Retention of your data

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate interests and that you are happy for us to do so. Accordingly, we have a data retention policy and run data routines to remove data that we no longer have a legitimate interest in maintaining.

We do the following to try to ensure that the data we hold on you is accurate:

• prior to making an introduction we check that we have accurate information about you;
• we keep in touch with you so you can let us know of changes to your personal data;

We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data include:

• the nature of the personal data;
• its perceived accuracy;
• our legal obligations;
• whether an interview or placement has been arranged; and
• our recruitment expertise and knowledge of the industry by country, sector and job role.

For your information,

Our current retention notice is available upon request.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for marketing purposes or if we intend to disclose your information to any third party for marketing purposes. We will collect express consent from you, if legally required, prior to using your personal data for marketing purposes.

You can exercise your right to accept or prevent processing for marketing purposes by checking the boxes on the forms we provide you when we collect your data. You can also exercise the right to not have your data used for marketing purposes at any time by contacting us via the website.

We may store and handle your data in the following ways:

• We may archive part or all of your personal data, retain it on our financial systems only or delete all or part of the data from our main Customer Relationship Manager (CRM) system.
• We may pseudonymise parts of your data, particularly following a request for restriction or

erasure of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.

Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliate. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

The UK GDPR provides you with the right to:

Access to information

The Data Protection Act 2018 and the UK GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete. Your right of access can be exercised in accordance with the Act and the UK GDPR.

A subject access request should be submitted to [email protected]. No fee will apply unless the requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character. In such circumstances, we may charge a fee or refuse to act on the request.

Changes to our privacy notice

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.

Contact

Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to [email protected].

Terms

“The Company” shall mean NC Associates

Use of this website is governed by this website policy and you agree to be bound by them each time you access the website.

The material on this website is provided purely for your information and you should seek further guidance and make independent inquiries before relying on it. The Company may make alterations to the website at any time. You will be deemed to accept such alterations when you next use the website following any such alteration.

Any employment placement will be subject to The Company’s current standard employment terms and conditions.

The information on this website is updated from time to time. Whilst The Company has made every effort to ensure the accuracy and completeness of information on this website, The Company makes no representations or warranties whatsoever, express or implied, as to the quality, accuracy or completeness of such information.

The Company may without notice modify, suspend or discontinue the website or any part of it at any time without any liability to you or any third party.

To the full extent permitted by law, The Company accepts no liability in contract, tort or otherwise (including liability for negligence), for loss or damage of any kind including without limitation, direct or indirect loss or damage, loss of business, revenue or profits, corruption or destruction of data, or any other consequential loss or damage arising out of your use or inability to use the website (or other site linked to the website) or in connection with any computer virus or system failure and The Company excludes any such liability even if The Company is expressly advised of the possibility of such damage or loss.

You will indemnify The Company against all costs, losses, expenses or other liabilities incurred by The Company arising from the use of the website by you.

Lawful Use

You will use the website for lawful purposes only.

Links

You should note that The Company provides links to web sites maintained by others. The Company accepts no responsibility or liability for the accuracy or legality of any content contained in such websites. The fact that you may use one of these links to access other websites is not an endorsement by The Company of any content contained in those websites. Neither you nor any third party may link another site to The Company’s website without The Company’s prior written consent.

Copyright

Unless otherwise stated, the copyright and similar rights in this web site and in all the material contained on this website belong to The Company. You are only permitted to copy or print extracts of the material for your own personal use. You may not use any of this material for commercial or public purposes.

Without The Company’s written permission, you may not (whether directly or indirectly including through the use of any programme) create a database in an electronic or other form by downloading and storing all or any part of the pages from this website. Without the permission of The Company, no part of this website may be reproduced, transmitted to or stored on any other website, disseminated in any electronic or non-electronic form, or included in any public or private electronic retrieval system.

Changes to these Terms and Conditions

The Company may add to or change this policy from time to time. You are deemed to have accepted changed or additional policy statements when you access the website following any such change or addition.

The Accuracy of your Registration Information

You are responsible for ensuring that any information you provide to The Company, including your CV, is accurate, complete and your own. If The Company has any reason to believe that any information you have supplied is false, inaccurate or not your own, we may remove your ability to log-in to the site and may prohibit you from using this site. The Company is entitled, forthwith and without notice, to remove from the website any such information found to be false, inaccurate, incomplete or not your own.

Your Username and Password

You are responsible for all use of this site made using your user name and password, whether or not such use is made by you or by someone else using your user name and password. You are responsible for protecting and securing your user name and password from unauthorised use. Your user name and password must not be disclosed to another person. If you believe there has been a breach of security of your user name or password, such as theft or your username or password becoming known to someone else or unauthorised use, you must notify The Company.

Information that you post on the website

The Company reserves the right, at your cost, at any time to remove any material from the site which it believes to be salacious, defamatory or offensive or which The Company believes may be in breach of a third party’s rights, such as a third party’s intellectual property or confidentiality rights. You agree to indemnify The Company on a full and continuing basis against any loss or damage suffered or costs (including legal costs) incurred by The Company in defending any action brought against The Company as a result of any information you have posted on the website.

Governing Law and Applicable Legislation

This website policy is governed by English law and you agree that the English courts shall have exclusive jurisdiction to determine any matter or dispute arising out of or in connection with use of this website and this policy.

It is not intended that a third party should have the right to enforce any provision of this policy pursuant to the Contracts (Rights of Third Parties) Act 1999 and furthermore The Company may, and without the consent of a third party to whom the right of enforcement of any of the terms has been expressly provided vary and amend this policy.

Use of this website may not be allowed in countries outside the United Kingdom where such use may be contrary to local law or regulation. If you access information on this website it is your sole responsibility to ensure compliance with any applicable laws or regulations in any other country. Any use of this website outside the United Kingdom is your responsibility and we accept no liability whatsoever in connection with such use.

The Company has the right at any time to terminate or suspend access to, or use of, the website where The Company reasonably believes you have infringed this policy.

NC Associates Ltd is Registered in England, with company number 010167103. Operating Under The Employment Agencies Act 1973.