For the purposes of this policy a Vulnerable Person will be the term used to cover children, young people and vulnerable Adults. This policy also has signs of abuse and abuse indicators attached.

A Vulnerable Person is deemed to be a child aged under 18 by law or an adult who is over the age of 16 and who is or may be in need of community care services. This could be by reason of mental or other disability, age, or illness, and who is or may be unable to take care of him/herself or unable to protect him/herself against significant harm or exploitation.

Làmhan is an inclusive charity and by the very nature of its work, has a responsibility to ensure that every Vulnerable Person using their services have a safe environment to learn and develop no matter their race, colour, religion, disability or financial circumstances. Where there are language barriers, we will seek support to ensure every child, young person or vulnerable adult has the same opportunities.

This      policy     has      been put in place by Làmhan to safeguard any Vulnerable Person using its services. This is in line with Health & Safety Rules & Regulations laid down by the law for people who work with children, young people, or vulnerable adults. And to ensure their rights to be safe are adhered to by all volunteers and staff.

Làmhan fully recognises its responsibilities for Vulnerable Person protection. This policy applies to ALL volunteers and staff recruited for or involved in our work.

Làmhan and all its appointed volunteers and staff believe that a Vulnerable Person has a right to be protected from physical, sexual, or emotional abuse, and neglect. They are our customers, and their welfare is the underpinning principle guiding this policy.

Responsibility

In        relation        to       the        work of   Làmhan

, who are not responsible for the day-to-day care of Vulnerable Persons, their volunteers and staff must also take responsibility for any child, young people, or adult during the period they are involved with or using our services.

Làmhan will protect Vulnerable Persons By:

•         Adopting a policy statement on safeguarding and the welfare of Vulnerable Persons (page 4 of this document)

•         Having a recruitment and selection policy for volunteers and staff

•         Providing an environment where all Vulnerable Persons feel safe, secure, and valued

•         Providing clear lines of communication, making all volunteers and staff aware of the groups’ policy on protecting Vulnerable Persons and know who they can approach with their concerns and be listened to.

•         Make all volunteers or any staff employed by the group aware of this policy and the procedures for dealing with situations concerning abuse and know how to identify and report possible cases of abuse

•         Make it clear to volunteers and staff that they have a role to play in protecting Vulnerable Persons from harm and that this applies to everyone and any work or service the group is involved in carrying out Disclosure Scotland checks on all volunteers or staff involved   with the work of the group.

•         Nominating a named Vulnerable Person Protection Officer (VPPO) and introducing a system whereby volunteers may take their concerns to and who will be responsible for handling any abuse situation (page 4 of this document).

•         Source appropriate training for the VPPO, charity, volunteers and staff to undertake to raise awareness and allow them to recognise situations where abuse may have taken place and know how to deal with situations of abuse.

•         Carrying out risk assessments and designing the work with Vulnerable Persons in mind and apply safety mechanisms were relevant for their protection

•         Treating all would-be volunteers as job applicants for any position involving contact with Vulnerable Persons

Safety Guidelines

It is our policy that volunteers and any staff recruited to work with or support our members must take responsibility for their concerns on safety. They must act on any suspicion or concern they have regarding the abuse or neglect of any Vulnerable Person when they are using our services. Volunteers and staff must pass on any concerns or disclosures made to them by any individual to the Vulnerable Persons Protection Officer whose responsibility it is to act on any information received, also to follow the guidelines laid out in this policy.

The Vulnerable Persons Protection Officer (VPPO) volunteers/staff should approach with any concerns or information on abuse is:

Name: Jo Watson Contact telephone No: 0735 911 8584

Rules of Care

All        volunteers        and        staff       of   Làmhan                          

should be aware that there may be other issues concerning a Vulnerable Person, for example, bereavement, divorce, bullying, offending etc. In any such cases volunteers and staff are expected to use a caring, non-judgemental attitude in their approach, to be a good listener, to offer appropriate support or other assistance with or for the Vulnerable Person.

•         If a Vulnerable Person wants to speak to you, give time to listen in a quiet but visible place. Avoid isolated situations out of sight, volunteers and staff should always avoid any situation where they are alone with any member of the group (male or female)

•         Volunteers and staff should always exercise great caution in physical contact with any member of the group

•         Be prepared for what you might hear, do not appear shocked, horrified, disgusted or angry

•         If the volunteer or member of staff feels the situation is one of immediate danger always call the emergency services (e.g. police, ambulance)

•         Remember to have regard for your own safety, leave the situation if it is not safe for you

•         Where the situation is safe, listen to the Vulnerable Person and give the necessary support and reassurance

•         Do not press them for details, do not make comments or judgements other than to show concern, do not confront the abuser

•         Issues of confidentiality must be clarified early on. For example, volunteers must make it clear that they will have to discuss the situation with the Vulnerable Person Protection Officer (VPPO) and tell them why

•         Where a Vulnerable Person expresses a wish for concerns not to be pursued then this should be respected wherever possible. However, decisions about whether to respect their wishes must have regard to the level of risk to the individual and others, and their capacity to understand the decision in question. In some circumstances their wishes may be overridden in favour of considerations of safety

•         Decisions to override the Vulnerable Person’s wish not to take the matter further should be the product of discussions with the VPPO

•         Volunteers and the VPPO should note any concerns and information given to them or witnessed by them

•         Do not seek evidence, support the Vulnerable Person, and log down any information given at this stage. All information may be used later for an effective formal investigation

•         All records of any incident concerning any member of the group should be kept in a locked confidential file

•         If a crime has been committed preserve any evidence without contaminating it. For example, if the person making the complaint uses bad language when explaining themselves, you should write it down word for word as they have said it

Vulnerable Person Protection Officer (VPPO) Procedure

In the first instance, if a volunteer informs the VPPO that a member has made a disclosure they should follow the procedures listed below:

•         Listen carefully to the volunteer or member of staff.

•         Listen carefully to what is being said by the Vulnerable Person, taking care to write it down word for word the way they have said it to you, for example, use of bad language to explain their situation. Also record the time and the date of the interview.

•         Allow the volunteer or member of staff to recount what was disclosed to them and in what context.

•         Find out how the volunteer or member of staff handled this and if commitments were made.

•         Do not promise confidentiality to the volunteer or staff member or the member making the disclosure.

•         Having carefully assessed the information, speak to the Vulnerable Person with the volunteer or member of staff present, both as support, a witness and to write down what the Vulnerable Adult is saying.

•         Reassure the member that they are not to blame but do not ask searching questions, it is not an interrogation.

•         Find out if anyone else has been told or if another agency may be involved, the Vulnerable Person may have already disclosed to someone in this agency who is dealing with it.

•         Suggest that they should not talk to anyone else about the matter.

•         Record the time and the date of the interview.

•         If satisfied that the above recommendations have been followed and there is cause for some concern or you are not sure what the next step should be, the VPPO should contact the proper support or helpline.

Vulnerable Person Protection Officer (VPPO) – GUIDELINES BEFORE REFERRAL

The decision to refer or not to refer should be made by the VPPO after they have learnt the following:

•            Have this policy, known indicators, and definitions of abuse to hand

•            Ensure the wishes of the Vulnerable Person and their right to self-determination has been accounted for

•            Gauge the seriousness of the abuse and the level of risk to the individual, take account of the effect of the abuse on the individual and the level of risk to others

•            Consider whether a criminal offence has been committed

•            Take account of the ability of others (the police, social work etc who may make a positive contribution to the situation - contact and ask for advice when not sure if a referral is needed)

Discussion and Consideration for Volunteers and Staff

Volunteers and staff with concerns should discuss these discreetly with the

Vulnerable Person Protection Officer (VPPO) in all circumstances as soon as possible after a disclosure has been made or suspicions of abuse are observed. If they are unavailable, then any concerns should be discussed with a member of the groups Management Committee. Staff and volunteer concerns about colleagues should be addressed initially with the Chairperson of the Management Committee, if this is not possible or the concern is about the Chairperson or other members of the Management Committee, they should refer the issue to the right support agency qualified to give the right advice. These are as follows:

For a Child or Young Person

The NSPCC Child Protection Helpline is 0808 800 5000, helpline advisers are all Child Protection Officers. If you have suspicions but are worried that there may be an innocent explanation, you can talk in confidence to the Helpline Adviser who will help you decide what to do. If necessary, where the child’s safety is at risk, they will pass the information on to social services to investigate the matter further.

Other contacts regarding adults are:

 For a Vulnerable Adult

Stirling Social Services            01786 233905

Out of hours                            01786 470500

General Descriptors for recognising types of abuse concerning Vulnerable Persons (Source:  NSPCC website July 2009)

There are different types of abuse that happen to Vulnerable Persons like physical, emotional, sexual abuse, and neglect. Below are general descriptors volunteers and staff should take account of when adhering to the groups Vulnerable Person Protection Policy

SIGNS OF ABUSE

The following may indicate abuse, but do not readily jump to conclusions.

Physical – unexplained or hidden injuries, unexplained bruising, lack of medical attention.

Emotional – reverting to younger behaviour, nervousness, sudden underachievement, attention seeking, running away and stealing or lying.

Sexual – pre-occupied with sexual matters evident in words, play, drawings, being sexually provocative with adults, disturbed sleep, nightmares, bedwetting, secretive relationships with adults or children, tummy pains with no apparent cause.

Neglect – looking ill-cared for and unhappy, being withdrawn or aggressive, having lingering injuries or health problems.

Child or Young Person

•                Physical – where children’s bodies are hurt or injured

This can happen by hitting, shaking, kicking, punching, scalding, suffocating and other ways of inflicting pain or injury to a child. It also includes giving a child harmful substances, such as drugs, alcohol, or poison. If a parent of carer reports non-existing symptoms of illness in a child, or deliberately causes illness in a child, this is also a form of physical abuse.

•                Emotional – where children do not receive love and affection, may be frightened by threats or taunts, or are given the responsibility beyond their years

This could be where a parent or carer behaves in a way that is likely to seriously affect their child’s emotional development. It can range from constant rejection and denial of affection, through to continual severe criticism, deliberate humiliation, and other ways of verbally “terrorising” a child.

•                Sexual abuse – is when a child or young person is pressurised, forced, or tricked into taking part in any kind of sexual activity with an adult or young person.

This can include kissing, touching the young person’s genitals or breasts, intercourse, or oral sex. Encouraging a child to look at pornographic magazines, videos or sexual acts is also sexual abuse.

•                Bullying – if you know or are told a child is being bullied you should try to help, always use a sympathetic and caring approach.

•                Listen to young people’s feelings and concerns

•                Help them to explore their options and do not take over

•                Talk to other adults, explore options

•                Encourage children to feel good about themselves – those who bully and the bullied often lack self-esteem

•                Encourage children to understand that we are all different, yet all equally important

•                Encourage children to think about their own and each others’ feelings.

•                Neglect – a persistent lack of appropriate care of children, including love, stimulation, safety, nourishment, warmth, education, and medical attention. This can have a serious effect on a child’s physical, mental and emotional development. For babies and very young children it can be life threatening.

DEFINITIONS OF ABUSE (Centre for Policy on Ageing 1996)

Abuse is the harming of another individual usually by someone who is in a position of power, trust, or authority over that individual. The harm may be physical, psychological, or emotional or it may be directed at exploiting their vulnerability in more subtle ways. For example, through denying access to people who can come to the aid of the person, or through misuse or misappropriation of his or her financial resources.

PHYSICAL ABUSE SIGNS

Please note: Some ageing processes can cause changes which are hard to distinguish from some aspects of physical assault e.g. skin bruising can occur very easily due to blood vessels becoming fragile.

•            A history of unexplained falls or minor injuries

•            Bruising in well protected areas, or clustered from repeated striking

•            Finger marks

•            Burns of unusual location or type

•            Injuries found at different states of healing

•            Injury shape similar to an object

•            Injuries to head; face; scalp

SEXUAL ABUSE SIGNS

•            Disclosure or partial disclosure (the use of phrases like ‘it’s a secret’)

•            Disturbed behaviour e.g. depression, sudden withdrawal form activities, loss of previous skills, self injury, showing fear or aggression to one particular person, inappropriate seduction behaviour.

•            Circumstances – e.g. two service users found in an isolated area, one in a distressed state

PSYCHOLOGICAL/EMOTIONAL SIGNS:

•            Isolation

•            Unkempt, unwashed, smell

•            Over meticulous

•            Inappropriately dressed

•            Withdrawn, agitated, anxious not wanting to be touched

•            Tearfulness

•            Unexplained paranoia or excessive fears

NEGLECT SIGNS

•            Physical condition poor

•            Clothing in poor condition

•            Untreated injuries or medical problems

•            Poor personal hygiene

FINANCIAL OR MATERIAL SIGNS

•            Unexplained or sudden inability to pay bills

•            Unexplained or sudden withdrawal of money from accounts

•            Disparity between assets and satisfactory living conditions

•            Extraordinary interest by family members and other people in the vulnerable person’s assets

DISCRIMINATORY SIGNS

•            Lack of respect shown to an individual

•            Signs of substandard service offered to an individual

•            Exclusion from rights afforded to others, such as health, education, criminal justice

OTHER SIGNS OF ABUSE

Where there is sensory deprivation e.g. where a vulnerable adult is prevented from getting access to their spectacles or hearing aid; restricted access to toilet and mobility equipment; and lack of personal clothing or possessions

PEOPLE WHO MIGHT ABUSE

Informal carer, family, friends; neighbours, paid staff, volunteers, other service users, tenants, Strangers

OUR EQUALITY AND DIVERSITY POLICY

Introduction

 Làmhan is committed to promoting an environment of respect, understanding, encouraging diversity, and eliminating discrimination by providing equality of opportunity for all. There will be a consistent approach in promoting equality and diversity across all areas within the charity, through the entire employment relationship from the recruitment process to termination and references.

All employees must abide by this policy. This policy also covers discrimination by and towards members of the public, governing body members, contractors, and staff from other agencies. The Organisation opposes all forms of unlawful discrimination in relation to employment.

Background

Tackling inequality is not something new. UK Governments have been addressing equality and diversity issues for many years. Although progress has been made, inequalities still exist in Scotland and within the UK. As the Government continues to tackle discrimination, promote equality, address inequalities and inconsistencies that were present in the previous discrimination legislation, the new Equality Act 2010 was introduced. The introduction of the act saw earlier discrimination legislation abolished and replaced with one single piece of legislation. This policy will be compliant with the current legislation and promote a culture of dignity and respect for all.

Lack of equal opportunities is not only a serious moral issue but also has a significant impact on business performance. Studies have shown that high levels of motivation are achieved in an environment of respect and fairness. The Organisation will aim to ensure that all employees are treated with fairness and respect and not be discriminated on the grounds of marriage & civil partnership, sex, race, disability, age, religion or belief, gender reassignment, pregnancy & maternity and sexual orientation, or disadvantaged by any conditions or requirements which cannot be shown to be relevant to performance.  The Organisation will therefore ensure all employees are provided with equality of opportunity in the course of their employment starting from recruitment.

Legal Framework

The following details the specific acts relating to discrimination law.

Equality Act 2010

Definitions

Diversity

Is about valuing individual differences. The Organisation is committed to valuing and managing people’s differences to enable all employees to contribute and realise their full potential. The Organisation recognises that people with diverse backgrounds, skills, attitudes, and experiences can bring fresh ideas and perceptions that will benefit The Organisation and its customers.

Equality

Is making sure people are treated fairly and given fair chances. Equality is not about treating everyone in the same way but recognises that their needs are met in different ways. Equality focuses on those areas covered by the law, and described as the Protected Characteristics of race, sex, disability, age, gender reassignment, marriage & civil partnership, pregnancy & maternity, religion or belief and sexual orientation

Protected Characteristics

The grounds on which discrimination claims can be made:

Age, Disability, Gender Reassignment, Marriage and Civil Partnership, Pregnancy & Maternity, Race, Religion or Belief, Sex, and Sexual Orientation.

Direct Discrimination

Is treating someone less favourably than others based on a protected characteristic.

Indirect Discrimination 

A policy, practice, procedure, provision, or criteria that applies to everyone in the same way but might disadvantage a particular protected group, and which cannot be objectively justified in relation to the job.

Harassment

Conduct that violates a person's dignity or creates an intimidating, hostile degrading, humiliating or offensive working environment. The intention of the perpetrator is irrelevant, it is the impact on the individual which determines whether harassment has taken place.

Victimisation

Treating someone less favourably and discriminating against them because they have pursued or intend to pursue their rights relating to alleged discrimination, complained about the behaviour of someone harassing them or given evidence in someone else’s discrimination compliant.

Positive Action

Addressing imbalances in the workforce, by encouraging members of underrepresented groups to apply for jobs. Positive action may be applicable in setting equality targets. No quotas will be set by the charity, but equality targets may be set to encourage people from a particular group or groups to apply for a vacancy in the charity in comparison to the local community where they are underrepresented.

Failure to make Reasonable Adjustments

Where arrangements disadvantage an individual because of a disability and reasonable adjustments are not made to overcome the disadvantage.

Associated Discrimination

Discrimination against a person because they have an association with someone with a particular protected characteristic. E.g. a non-disabled person is discriminated against because of the action they need to take care of disabled dependent.

Perceptive Discrimination

Discrimination against a person because the discriminator thinks the person posses that characteristic. E.g. a person is not shortlisted for a job on the bases that the recruiter assumes the applicant does not have the correct VISA to work in the UK as they have a foreign looking name on their application form.

Employees

All permanent, temporary fixed term staff, including all managers, Director/Chief Executive, and agency workers.

Stakeholders

Contractors, consultants, tenants, customers, service users, other outside agency workers

Policy Principles

This Equality and Diversity policy aims to:

·      Ensure integration with equality and diversity practices into all the charity does and ensure that employees are treated with fairness and respect from each other and from members of the public, committee members, and contractors.

·      Require the charity to implement fair and just employment practices ensuring that no job applicant or employee will receive less favourable treatment on any grounds.

·      Ensure people are recruited and employees promoted solely on the basis of their own merit, experience, ability, and potential. This applies throughout the entire duration of employment as all decisions will be based on only relevant merits.

·      Provide an environment appropriate to the needs of those from all walks of life and offer a culture that respects and values each others' differences and promotes dignity, equality, and diversity.

Implementation of Policy

The Board is responsible for the policy’s day to day implementation.

The charity will ensure that all new employees and management committee members will receive induction on this policy. The policy will be widely promoted and integrated into all policies and procedures within the charity. Copies of the policy will also be freely available and displayed in the charity’s offices. Appropriate training and guidance will be available to promote equality and diversity among staff.

This policy applies to everyone in the charity, and everyone has a responsibility to be alert to discriminatory behaviours and practices should they occur. Unacceptable behaviour and practices must not occur, however if a situation arises, it will be dealt with immediately.  Breaches of the equality and diversity policy will be regarded as misconduct and will lead to disciplinary action which may include dismissal.

Recruitment & Selection

It is the charity’s policy that all recruitment decisions will be based completely on the merits and abilities of candidates alone and no other criteria will be used. In order to achieve this, equality and diversity practices will be integrated into every stage of the recruitment and selection process.

A fair recruitment process will remove barriers to the employment of people of different backgrounds. This will enable the charity to recruit from the widest pool of talent, potentially raising the standard of their intake and therefore increasing the opportunity of a more diverse workforce which reflects the community it is serving. A more diverse workforce will improve the organisation’s service delivery, as it will include staff with more knowledge and experience, meet and aid in meeting the needs and aspirations of service users and potential service users.

To highlight the charity’s commitment to promoting equality and diversity from the beginning of the employment relationship, all vacancies will be aimed at as wide a group as possible and any advertisement for a vacancy within the charity will state that an equality and diversity policy is in place. In addition, the advert will also display any signs of equality bodies that the charity is affiliated with. The information contained in the advert and all vacancy literature will be clear and accurate to attract the most appropriate candidates from all groups across society, to allow them to decide their own suitability for the vacancy and whether they wish to proceed with applying. For those that wish to apply the charity will ensure that all applications have clear instructions for completion and application forms will be free from personal questions that are not relevant to the vacancy and that may lead to discrimination.

The charity will ensure all staff involved at any stage in the recruitment and selection process will receive equality and diversity awareness training. This will ensure that those involved in the recruitment process will not discriminate either knowingly or unknowingly by asking any questions which may lead to discrimination.

Terms & Conditions of Employment

As part of the employment relationship being covered under this equality and diversity policy all contracts of employment will be issued in accordance with the job role and not the job holder. Employee’s terms and conditions will be standard across all employees regardless of any of the protected characteristics. Employees will not receive less favourable terms and conditions for any reason other than relating specifically to the job role and the grade it attracts.

Training and Development

Equality and diversity will apply throughout all training activities and resources. Training and development opportunities will be given to all employees according to their job role. It is crucial that all employees can participate and enjoy any training opportunities or activities without discrimination or fear of harassment. Every attempt will be made to ensure learning materials will provide a positive image of people reinforcing an image and of equality of opportunity.

Redundancy Selection

Redundancy selection will be made according to the statutory requirements and in line with The Organisation’s Redundancy Policy contained in the terms and conditions.   Criteria will be discussed with a Trade Union and or nominated representatives. The criteria will be set out and will be objectively fair and consistent. This will ensure that employees selected for redundancy are selected according to the chosen selection criteria and not in any discriminatory way either indirectly or directly.

Complaints: employees

This procedure is complemented by the charity’s Dignity at Work policy. For further details please refer to the policy.

Where an employee feels they have been discriminated against, victimised or harassed by another employee (including managers), the aim should be to deal with it informally in the first instance.

Informal Stage

An employee should aim to resolve the matter informally as it may be that the discriminatory action is unconscious and easily resolved once the situation is highlighted.  This is often the most efficient way with dealing with such circumstances and helps maintain good working relations.

The employee should raise the issue informally with their line manager (if the complaint is against their manager, then the manager next in line.) The manager will speak to the employee whom the complaint is against. If it is found that the behaviour was in breach of this policy, an appropriate level of sanction will be decided in line with the charity’s Disciplinary Policy.

In addition, a file note of the incident will be kept on the complaining employee’s file, including a statement that the note will only be taken into account if there are any further incidents.

Dealing with the matter informally does not remove the complaining employee’s right to have the matter dealt with formally.

Formal Stage

If the employee is dissatisfied with the outcome, or the complaint is very serious, they should raise the matter in writing, detailing the complaint to their line manager. The complaint should then be dealt with under the charity’s Grievance Policy. In line with this process an investigation into the complaint will be carried out. Employees who feel they are being subjected to harassment should raise the issue in line with The Organisation’s Dignity at Work Policy.

If the outcome of the investigation is that a formal disciplinary hearing should take place this will be conducted in line with the charity’s Disciplinary Procedures. (Please refer to the Disciplinary Policy for full details)

Complaints made against employees

Where a complaint is made against an employee by another employee, Board/Committee member or stakeholder, it will be investigated and dealt with under the charity’s Disciplinary Policy.

Complaints: Stakeholders

The right to be treated equally with dignity and respect extends to outside contractors, partners, service users, customers and any other agencies that are associated with the charity. Therefore, stakeholders also have a right to have any issues addressed under this policy. Any complaints will be investigated by the charity and appropriate action will be taken.

If a stakeholder feels that they are being discriminated against in the course of their working day with the charity, the following procedure should be followed.

Informal Stage

Where possible, incidents should be dealt with informally. The stakeholder should report the matter to their lead contact within the charity as soon as possible. It maybe that the discriminatory action is unconscious and easily resolved once the situation is highlighted.

The manager will discuss the situation with the individual whom the complaint is against and explain the expected standards of behaviour and the consequences of not complying with these. It will be made clear to the individual that continuation of such conduct may result in being refused access to The Organisation’s premises, or services.

Formal Stage

Where informal action is not appropriate, or the matter is of a serious nature the complaint will be dealt with using the formal procedure. Where the formal procedure is instigated, a thorough investigation will take place in the first instance. Where it is found that the individual has acted in an inappropriate manner, they will be written to officially by the relevant senior manager informing them that their comments, actions, behaviours are not acceptable and potentially discriminatory. The letter will state that further incidents will not be tolerated and that they may result in being refused access to the charity’s premises or contact with its customers/employees/board members. In cases of physical violence or serious threats the appropriate manager will notify the police.

Complaints made by stakeholders

Where stakeholders are in receipt of inappropriate behaviour from an employee of the charity, board member or another stakeholder in connection with the charity’s business, the stakeholder should also raise the issue with their lead contact. The lead contact will then investigate into the complaint and deal with it in accordance with the appropriate procedure (depending on whether the complaint is against an employee, a board member, a contractor, a partner, etc.).

Complaints: Governing Body Members

Where a board/committee member feels they have been discriminated against, victimised, or harassed, the aim should be to deal with it informally in the first instance.

Informal Stage

If a board/committee member feels they are in receipt of inappropriate behaviour from another board/committee member, an employee, or any stakeholder in connection with the charity, they should raise this immediately with the appropriate senior manager. The manager will discuss the issue with whom the complaint is against, explaining the required standards of behaviour and the consequences of failing to comply.

Formal Stage

Where formal action is the most appropriate, and thorough investigation will take place into the complaint. The complaint then will be dealt with in accordance with the appropriate procedure (depending on whether the complaint is against an employee, a board member, a contractor, a partner, etc.). In cases of physical violence or serious threats an appropriate manager will notify the police.

Complaints made against a board/committee member

Where a complaint is made against a board/committee member, The Organisation’s board/committee complaints procedure will be used as appropriate. The complaint will be investigated by the Chair or another authorised person. If it is found that the inappropriate behaviour occurred, the board/committee member will be warned and informed of consequences of failure to comply with the expected standards of behaviour, which may include removal from the board/committee.

Monitoring the Policy

Responsibility for monitoring the application of this policy will rest with the Board.

The policy will be reviewed annually with the amendments being made as appropriate and communicated to all staff and relevant stakeholders.

OUR COMPLAINTS POLICY

Complaints should be in writing via email Jo Watson, CEO, to hello@lamhan.org.uk

 Aims

Làmhan (hereinafter ‘The Charity’) aims to provide the best possible service, but if we should, in your opinion, fall short of the high standards we set, there is a redress procedure which you can use.

Stage One

In the first instance the complaint should be dealt with by the manager responsible for the issue/ service being complained about. They may be able to resolve it swiftly and should do so if possible and appropriate.

Complaints received about Trustees should be referred to the Chief Executive in the first instance, who will refer to the Chair. If the complaint relates to a member of staff/volunteer/Trustee/Committee member, they should be informed and given a fair opportunity to respond.

Complaints should be acknowledged by the person handling the complaint within a week. The acknowledgement should say who is dealing with the complaint and when the person complaining can expect a reply.

A copy of this complaints procedure should be attached. Ideally complainants should receive a definitive reply within four weeks.  If this is not possible because for example, an investigation has not been fully completed, a progress report should be sent with an indication of when a full reply will be given.

Whether the complaint is justified or not, the reply to the complainant should describe the action taken to investigate the complaint, the conclusions from the investigation, and any action taken as a result of the complaint.

Stage Two

If the complainant feels that the problem has not been satisfactorily resolved at Stage One, they can request that the complaint is reviewed at Senior Management/Chief Executive level.  At this stage, the complaint will be passed to the Chief Executive’s Office. The Chief Executive’s Office will log the complaint and response to Stage 2.

The request for review should be acknowledged within a week of receiving it.  The acknowledgement should say who will deal with the case and when the complainant can expect a reply. If the complaint relates to a specific person, they should be informed and given a further opportunity to respond.

The person who dealt with the original complaint at Stage One should be kept informed of what is happening. Ideally complainants should receive a definitive reply within four weeks. If this is not possible because for example, an investigation has not been fully completed, a progress report should be sent with an indication of when a full reply will be given.  Whether the complaint is upheld or not, the reply to the complainant should describe the action taken to investigate the complaint, the conclusions from the investigation, and any action taken as a result of the complaint.

Stage Three

If the complainant still feels that they have not received a satisfactory response from Stage 2 then the matter may be referred for consideration by the Board.  The complainant and any persons/ staff involved in the case should be kept informed. The decision taken at this stage is final, unless the Board decides it is appropriate to seek external assistance with resolution.

Complaints to the Office of the Scottish Charity Regulator (OSCR)

The complainant can complain to OSCR at any stage:

Quadrant House, 9 Riverside Dr, Dundee, Dundee City DD1 4NY

01382 220446

info@oscr.org.uk

http://www.oscr.org.uk/contact-oscr/charity-complaint-form

Variation of the Complaints Procedure

The Board may vary the procedure for good reason such as to avoid a conflict of interest. If this occurs all parties involved will be informed of the changes and the rationale. Monitoring and learning from complaints.

Complaints reaching Stage 2 and above are logged by the Chief Executive’s Office. These records are reviewed to identify any trends in relation to frequency and resolution of complaints and to enable the Organisation to learn from and enhance its services as necessary.

LAMHAN’S DATA PRIVACY NOTICE

Your personal data – what is it?

Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the “GDPR”)

Who are we?

Làmhan is the data controller (contact details below). This means it decides how your personal data is processed and for what purposes.

How do we process your personal data?

·      Làmhan complies with its obligations under the GDPR by keeping personal data up to date;

 ·      by storing and destroying it securely; by not collecting or keeping excessive amounts of data;

 ·      by protecting personal data from loss, misuse, unauthorised access, and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. We use your personal data for the following purposes: - (examples shown below)

o   To enable us to provide a service for the benefit of the public as specified in our constitution;

o   To administer membership records;

o   To fundraise and promote the interests of the charity;

o   To manage our employees and volunteers;

o   To maintain our own accounts and records;

o   To operate the web site and deliver the services that individuals have requested;

o   To inform individuals of news, events, activities, or services;

o   To process Gift Aid applications;

o   To contact individuals via surveys to conduct research about their opinions of current services or of potential new services that may be offered.

What is the legal basis for processing your personal data?

These fall under either article 6 or article 9 – dealt with separately below.

[You will need to insert here the relevant processing condition contained in Article 6 of the GDPR – e.g. consent, legitimate interests of the data controller etc.]

E.g. Article 6 processing

·      Consent of the data subject; [Where the processing is based on the consent of the data subject, you will need to provide a link to the “Consent Form” at the end of this notice].

·      Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract [If so, insert details of the contract];

 ·      Processing is necessary for compliance with a legal obligation; [You will need to provide details of whether there is a statutory or contractual requirement to provide the data and if so, the consequences of not supplying the data].

• Processing is necessary to protect the vital interests of a data subject or another person;

• Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller;

·      Processing is necessary for the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject.

E.g. Article 9 Processing

·      Explicit consent of the data subject 

·      Processing is necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement;

·      Processing is necessary to protect the vital interests of a data subject or another individual where the data subject is physically or legally incapable of giving consent;

·      Processing is carried out by a not-for-profit body and the processing relates only to members or former members (or those who have regular contact with it in connection with those purposes); and there is no disclosure to a third party without consent. [This clause allows you to collect and process data without consent]

·      Processing relates to personal data manifestly made public by the data subject;

·      Processing is necessary for the establishment, exercise or defence of legal claims or where courts are acting in their judicial capacity;

·      Processing is necessary for reasons of substantial public interest on the basis of EU or Member State law;

·      Processing is necessary for reasons of preventative or occupational medicine, for assessing the working capacity of an employee, medical diagnosis, the provision of health or social care or treatment or management of health or social care systems and services on the basis of EU or Member State law or a contract with a health professional;

·      Processing is necessary for the reasons of public interest in the area of public health;

·      Processing is necessary for archiving purposes in the public interest, or scientific and historical research purposes or statistical purposes. [Where the personal data are collected direct from the data subject, the data subject must be informed whether he or she is obliged to provide the personal data and the consequences, if he/she does not provide the data].

Sharing your personal data

Your personal data will be treated as strictly confidential, and will be shared only internally within the charity.

We will only share your data with third parties outside of the organisation with your consent.

How long do we keep your personal data?

We keep your personal data for no longer than necessary for a period of two years in case of any legal claims/complaints and for safeguarding purposes if necessary.

Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: -

·      The right to request a copy of your personal data which the charity holds about you;

·      The right to ask that the charity corrects any personal data if it is found to be inaccurate or out of date;

·      The right to request your personal data is erased where it is no longer necessary for the charity to retain such data;

·       

·      The right to ask that the charity provides the data subject with his/her personal data and where possible, to send that data directly to another data controller, (known as the right to data portability), (where applicable)

*Only applies where the processing is based on consent or is necessary for the performance of a contract with the data subject and in either case the data controller processes the data by automated means].

·      The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;

·      The right to object to the processing of personal data, (where applicable) [Only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics]

·      The right to lodge a complaint with the Information Commissioners Office.

Further processing

 If we wish to use your personal data for a new purpose, not covered by this Data Protection Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

Where and whenever necessary, we will seek your prior consent to the new processing. Contact Details To exercise all relevant rights, queries of complaints please in the first instance, contact us via email at hello@lamhan.org.uk.

 HEALTH AND SAFETY NOTICE

PART ONE

General Statement of Policy, Duties & Responsibilities

1.1          Policy Statement

Làmhan (hereinafter  ‘The Charity’) recognises and accepts its health and safety duties for providing a safe and healthy working environment (as far as is reasonably practicable) for all its workers (paid or volunteer) and other people using its services and/or visiting its premises under the Health and Safety at Work Act 1974, other relevant legislation and common law duties of care.

Throughout this Statement, terms such as “staff”, “workers”, “employees”, include both paid and volunteer workers.

It is the policy of the Charity to promote the health and safety of the committee members, volunteers, staff and of all visitors to the Charity’s premises (“the Premises”) and to that intent to:

• Take all reasonably practicable steps to safeguard the health, safety and welfare of all personnel on the premises;

• Provide adequate working conditions with proper facilities to safeguard the health and safety of personnel and to ensure that any work which is undertaken produces no unnecessary risk to health or safety;

• Encourage persons on the premises to co-operate with the Charity in all safety matter, in the identification of hazards which may exist and in the reporting of any condition which may appear dangerous or unsatisfactory;

• Ensure the provision and maintenance of plant, equipment and systems of work that are safe;

• Maintain safe arrangements for the use, handling, storage and transport of articles and substances;

• Provide sufficient information, instruction, training and supervision to enable everyone to avoid hazards and contribute to their own safety and health;

• Provide specific information, instruction, training and supervision to personnel who have particular health and safety responsibilities (eg a person appointed as a Health and Safety Officer or Representative);

• Make, as reasonably practicable, safe arrangements for protection against any risk to health and safety of the general public or other persons that may arise for the Charity’s activities;

• Make suitable and sufficient assessment of the risks to the health and safety of employees and of persons not in the employment of the charity arising out of or in connection with the charity’s activities;

• Make specific assessment of risks in respect of new or expectant mothers and young people under the age of eighteen;

• Provide information to other employers of any risks to which those employer’s workers on the Organisation’s premises may be exposed.

This policy statement and/or the procedures for its implementation may be altered at any time by the Charity’s Management Committee (“the Committee”). The statement and the procedures are to be reviewed each year. A report on the review, with any other proposals for amendment to the statement of procedures, is to be made to the next following ordinary meeting of the Management Committee.

1.2          Statutory Duty of the Group

The Charity will comply with its duty to ensure, as far as is reasonably practicable, the health, safety and welfare at work of its workers and of users of its services and/or visitors to its premises and, in general, to:

• Make workplaces safe and without risks to health;

• Ensure plant and machinery are safe and that safe systems of work are set and followed;

• Ensure articles and substances are moved, stored and used safely;

• Give volunteers/ workers the information, instruction, training and supervision necessary for their health and safety.

In particular, the Charity will:

• Assess the risks to health and safety of its volunteers/workers;

• Make arrangements for implementing the health and safety measures identified as necessary by this assessment;

• Record the significant findings of the risk assessment and the arrangements for health and safety measures;

• Draw up a health and safety policy statement; including the health and safety organisation and arrangements in force, and bring it to the attention of its workers;

• Appoint someone competent to assist with health and safety responsibilities;

• Set up emergency procedures;

• Provide adequate First Aid facilities;

• Make sure that the workplace satisfies health, safety and welfare requirements, eg for ventilation, temperature, lighting and for sanitary, washing and rest facilities;

• Make sure that work equipment is suitable for its intended use as far as health and safety is concerned, and that it is properly maintained and used;

• Prevent or adequately control exposure to substances that may damage health;

• Take precautions against danger form flammable or explosive hazards, electrical equipment, noise or radiation;

• Avoid hazardous manual handling operations and, where they cannot be avoided, reduce the risk of injury;

• Provide health surveillance as appropriate;

• Provide free any protective clothing or equipment, where risks are not adequately controlled by other means;

• Ensure that appropriate safety signs are provided and maintained;

• Report certain injuries, diseases and dangerous occurrences to the appropriate health and safety enforcing authority.

1.3          Statutory Duty of the Charity’s Workers

Employees also have legal duties, and the Charity confidently requests non-employed (voluntary) workers also to observe these. They include the following:

• To take reasonable care for their own health and safety, and that of other persons who may be affected by what they do or do not do;

• To co-operate with the Charity on health and safety;

• To use work items provided by the Organisation correctly, including personal protective equipment, in accordance with training or instructions;

• Not to interfere with or misuse anything provided for health, safety and welfare purposes;

• To report at the earliest opportunity injuries, accidents or dangerous occurrences at work, including those involving the public and participants in activities organised by the Charity;

• Health and Safety law applies not only to employees in the workplace, it also applies to organisations and people who occupy or use community buildings to which members of the public have access.

1.4          Policy for Visitors and Contractors

On arrival all visitors should be directed to the duty representative of the Management Committee, or a representative of the user/hirer of the building. This person is to take responsibility for the visitor(s) and assist in their evacuation from the building during an emergency or arrange help in the event of an accident.

On arrival, all visitors, including contractors and/or their workers, must sign a record of the date and time of their arrival and, before leaving, should further record their time of departure.

Contractors working in the building should report any concerns relating to their own safety or suspected unsafe working practices to the Duty representative of the Committee who will investigate and report to the Organisation.

PART TWO

Organisation of Health and Safety

2.1          Health and Safety Rules

All workers must exercise ordinary care to avoid accidents in their activities at work and follow the following general rules and with any further rules which the Organisation may publish from time to time.

Accident Forms and Book

The book must be kept in a locked drawer once completed.

Any injury suffered by a worker or visitor in the course of employment or otherwise on the Charity’s premises, however slight, must be recorded, together with such other particulars as are required by statutory regulations, on an accident form kept by the Charity.

Fire Precautions

All personnel must familiarise themselves with fire escape routes and procedures and follow the directions of the Charity in relation to fire.

Equipment and Appliances 

No equipment or appliance may be used other than as provided by or specifically authorised by or on behalf of the Charity and any directions for the use of such must be followed precisely.

Safety Clearways

Corridors and doorways must be kept free of obstructions and properly lit.

Maintenance

Defective equipment, furniture and structures must be reported as such without delay.

Hygiene and Waste Disposal

Facilities for the disposal of waste materials must be kept in a clean and hygienic condition.  Waste must be disposed of in an appropriate manner and in accordance with any special instructions relating to the material concerned.

Food Hygiene

When handling or preparing food there are specific hygiene requirements:

• Regularly wash hands before and during food preparation and especially after using the lavatory;

• Tell your supervisor or representative of the Committee of any skin, nose, throat, or bowel problem;

• Ensure cuts or sores are covered with correct waterproof dressings;

• Keep yourself clean and wear clean clothing;

• Remember that smoking in a food room is illegal;

• Never cough or sneeze over food;

• Clean as you go.  Keep all equipment and surfaces clean.

•  

Display Screen Equipment

The Charity recognises its responsibility to ensure the well-being of workers who habitually use display screen equipment for a significant part of their normal work. Volunteers/Workers are advised to ensure that they take a five minute break from the display screen equipment at least once an hour and are advised that, if they experience vision defects or other discomfort that they believe may be wholly or in part a consequence of their use of such equipment, they have the right to an eye-test at the Charity’s expense.

Alcohol, Drugs and Tobacco 

Smoking within the premises and the use of Drugs (except under medical supervision) on the premises are prohibited at all times. The use of intoxicants (alcohol) is prohibited during working hours, and no employee/volunteer may undertake his/her duties if under the influence of alcohol or drugs (except under medical supervision)

PART THREE

Arrangement and Procedures

The Health and Safety Officer, nominated by the Management Committee, is responsible for ensuring that the safety policy is carried out and that responsibilities for safety, health and welfare are properly assigned and accepted at all levels. Her details and contact number will be displayed in the studio space.

3.1          First Aid and Accident Reporting

3.2          Fire Drills and Evacuation Procedures

3.1.1   First Aid

·      The current First Aider(s) for the premises is/are displayed  (on the Notice Board in the Reception Area).

·      First Aid Boxes are provided in the following location(s):

i)               Reception

ii)              Kitchen

3.1.2     Accidents

·      In the event of an injury or illness, call for a member of staff or ring for an ambulance directly.  To call an ambulance – dial 999 and ask for “ambulance”;

·      All accidents must be reported to the Health and Safety Officer or another member of staff on duty immediately or as soon as practicable;

·      All accidents must be entered on an accident form, available from the reception desk.  The procedures for “notifiable” accidents as shown in Appendix A below must be followed;

·      The Health and Safety Officer will investigate incidents and accidents, writing a detailed report for the Charity’s Management Committee to consider the actions necessary to prevent recurrence.

3.3          Fire Drills and Evacuation Procedures

3.2.1     Fire Drills

·      All workers and volunteers must know the fire procedures, position of fire appliances and escape routes.

·      The fire alarm points, fire exits and emergency lighting system will be tested by The Fire Officer/Health and Safety Officer during the first week of each month and entered in the log book provided.

·      The Fire Officer will arrange for Fire Drills and Fire Prevention Checks (see Appendix C below) to be carried out at least once every three months and entered in the log book.  In addition, these Drills will be carried out at different times and on different days, so that all users/hirers know the procedures.

·      The last person securing the premises will ensure Fire Prevention Close Down Checks are made of all parts of the premises at the end of a session (See Appendix C).

3.2.2    in the event of Fire

·      Persons discovering a fire should sound the nearest alarm;

·      The first duty of all workers is to evacuate all people from the building by the nearest exit immediately the fire is discovered;

·      All persons must evacuate the building and, where possible without personal risk, leave all doors and windows closed;

·      The assembly point for the building is at the …………………………………

·      No-one should leave the assembly point without the permission of a member of staff;

·      If any fire occurs, however minor, the Fire Brigade must be called immediately by dialling 999 and asking for “Fire”;

·      When the Fire Brigade arrives advise whether all persons are accounted for and location of fire.

3.2.3     Cleaning Materials, General Machinery and High Risk Areas

·      All portable machinery must be switched off and unplugged when not in use;

·      Wandering cables are a hazard; use with caution and safety in mind;

·      Slippery floors and dangerous; use warning signs;

·      Use protective clothing and equipment provided and as instructed on machinery/equipment/material.  It is the duty of a worker to report any loss of or defect in protective clothing or equipment.

3.2.4     General

·      All thoroughfares, exits and gates must be left clear at all times;

·      Corridors and fire exits must not be blocked by furniture or equipment;

·      Vehicles must not be parked near to the building so as to cause any obstruction or hazard;

·      Hazards or suspected hazards or other health and safety matters should be reported to the Health and Safety Officer or the staff member on duty immediately or as soon as practicable, so that action can be taken.  If the hazard is of a serious nature, immediate action must be taken to protect or clear the area to prevent injury to staff or other users.

PART FOUR

Appendices

APPENDIX A – ACCIDENT REPORTING

1.    Accidents

All accidents which occur during work for the Charity and/or for the User/Hirer, or on premises under the control of the Group/Organisation must be recorded.

2.    Accidents to Workers or Contractor’s Staff

a)     For ALL Accidents

Complete Accident Form and give to Health & Safety Officer

b)     For accidents reportable to the Health & Safety Executive

http://www.hse.gov.uk/riddor/report.htm

3.    Accidents to Members of the Public

1.     For ALL Accidents

Complete Accident Form and give to Health & Safety Officer

2.     For accidents reportable to the Health & Safety Executive

http://www.hse.gov.uk/riddor/report.htm

Some injuries may not be fully identified until the casualty has been to hospital.  It is therefore essential that, if it is known that an individual has gone to hospital as a result of an accident, follow up action is carried out.

IF IN DOUBT REPORT IT

Full details of Specified Injuries to Workers, Dangerous Occurrences, Carcinogens, Mutagens and Biological agents, and Occupational Diseases can be found in http://www.hse.gov.uk/riddor/index.htm

Appendix B – CONTROL OF SUBSTANCES HAZARDOUS TO HEALTH (COSHH REGULATIONS)

1.    Assessment

The assessment must be a systematic review

o   What substances are present and in what form?

o   What harmful effects are possible?

o   Where and how are the substances actually used or handled?

o   What harmful effects are given off, etc.?

o   Who could be affected, to what extent and for how long?

o   Under what circumstances?

o   How likely is it that exposure will happen?

o   What precautions need to be taken to comply with the COSHH Regulations?

o   What procedures need to be put in place to comply with the Control of Asbestos at Work Regulations 2002?

2.    Prevention or Control

Employers have to ensure that the exposure of workers to hazardous substances is PREVENTED or, if this is not reasonably practicable ADEQUATELY CONTROLLED.

On the basis of the assessment, the employer has to decide which control measures are appropriate to the work situation in order to deal effectively with any hazardous substances that my present.  This may mean PREVENTING exposure by

o   Removing the hazardous substance by changing the process

o   Substituting with a safe or safer substance, or using a safer form

Or, here this is not reasonably practicable, CONTROLLING exposure by

o   Totally enclosing the process

o   Using partial enclosure and extraction equipment

o   General ventilation

o   Using safe systems of work and handling procedures

It is for the employer to choose the method of controlling the exposure and to examine and test control measures, if required.

The Regulations limit the use of Personal Protective Equipment (e.g. dust masks, respirators, protective clothing) as the means of protection of those situations ONLY where other measures cannot adequately control exposure.

Employers must provide any of their workers and, so far is reasonably practicable, other persons on site who may be exposed to substances hazardous to health, with suitable and sufficient information, instruction and training to that they know the risks they run and the precautions they must take.

Employers must ensure that anyone who carries out any task in connection with their duties under COSHH has sufficient information, instruction and training to to the job properly.

Appendix C – FIRE PREVENTION

1.     Has the Fire brigade been consulted on:

o   The number and width of escape routes so as to provide a ready means of escape from all parts of the premises?

o   Emergency lighting and its maintenance?

o   The most suitable way of raising an alarm in the event of fire?

o   The contents of fire instruction notices?

o   The numbers and types of fire extinguishers or other fire-fighting appliances which should be provided?

o   Precautions to be taken with any activities involving the use of flammable liquids, naked flames or heating processes?

o   The desirability of battening or clipping seats together in sets of four where moveable seats are used for large audiences?

o   The maximum number of people who should be allowed on the premises at any one time?

o   Are seating and gangways in the hall/rooms so arranged as to allow free and easy access direct to fire exits?

o   Are exit doors always unlocked before the start of any session and kept unlocked until the last person leaves?

o   Are escape routes and exit doors clearly sign-posted and marked so that anyone not familiar with the building can quickly see the ways out?

o   Are escape routes and exit doors never allowed to become obstructed or hidden by chairs, stage props, curtains etc.?

2.     Is Fire Equipment properly looked after?

o   Are fire extinguishers, hose reels and fire alarm systems (where provided) regularly maintained by specialist fire engineering firms?

o   Are staff/duty officers trained to use this equipment?

o   Is equipment kept in its proper position and always clearly visible and unobstructed?

3.     Are thorough close-down checks made of all parts of the premises at the end of an evening or session?

o   No smouldering fires or cigarettes left burning?

o   Heater and cookers turned off?

o   Televisions and other electrical apparatus turned off and unplugged?

o   Lights off?

o   Internal doors closed?

o   Outside doors and windows closed and secured?

4.     Are all reasonable steps taken to prevent fires?

o   Smoking not allowed in store rooms or backstage?

o   Substantial ashtrays provided in areas where smoking is permitted?

o   Heating appliances fitted with adequate and secure fire guards?

o   If portable heaters have to be used, are they securely fixed and kept away from combustible materials?

o   Precautions to ensure that convector type heaters are not covered with clothes and curtains?

o   Temporary extensions or additions to the electrical installation carried out and checked by a competent electrician?

o   Sufficient socket outlets provided to obviate the need for long trailing flexes?

o   Damaged leads replaced regularly?

o   Cooking operations supervised by a reliable person?

o   Scenery, decorations and costumes for stage performances treated to make them flame retardant?

o   All parts of the premises kept clear of waste and rubbish, particularly staircases, space under stairs, store rooms, attics and boiler rooms?

Appendix D – HEALTH AND SAFETY INSPECTION

1.     Inspection

o   A Health and Safety inspection of the building should be undertaken at least every six months.  One of these inspections may be undertaken at the same time as the annual building maintenance check.

o   Appointed members of the Management Committee, or a sub-group, should arrange to meet and carry out the inspection

o   This inspection group will need to agree how each question needs to be answered

o   When the form is complete and has been signed, matters noted as not satisfactory, together with any other concerns raised by the inspection, should be reported to the Management Committee.

o   The inspection group should be authorised, where URGENT action is necessary, to make immediate reasonable response

o   The whole form should be made available to members of the Management Committee

o   The forms should be preserved in a file maintained for this purpose.  As required action is taken, the responsible person should initial the form in the appropriate box

2.     Risk Assessment

o   Risk assessments relate to activities within the premises or grounds

o   Risk assessments NEED to be carried out in relation to every activity undertaken, whether by groups or individuals and including the work of paid staff AND volunteers

o   Special attention should be paid to the circumstances of workers under the age of eighteen and to expectant mothers, women who have given birth within the past six months or who are breastfeeding

o   A risk assessment needs to be carried out whenever a new activity is envisaged

o   Assessments need to be repeated whenever circumstances change:

§  Changes in layout of equipment

§  Observing trends on the accident form

§  Changes in staff

§  Introduction of new procedures, processes or materials

Appendix E – DISPLAY SCREEN EQUIPMENT

1.     Who is a Display Screen User?

The regulations are for the protections of workers (including self-employed workers and volunteers) who habitually use display screen equipment for a significant part of their normal work.

In some cases it will be clear that the use of Display Screen Equipment is more or less continuous on most days and the individual concerned should be regarded as users.  Where use is less continuous, ‘user’ status would apply if most or all of the following criteria are met:

o   The individual depends on the use of display screen equipment to do the job, as alternative means are not readily available for achieving the same results.

o   The individual has no discretion as to the use or non-use of the display screen equipment

o   The individual needs significant training and/or particular skills in the use of display screen equipment to do the job

o   The individual uses display screen equipment in this way more or less daily

o   Fast transfer of information between the user and the screen is an important requirement of the job

o   The performance requirements of the system demand high levels of attention and concentration by the user; for example where the consequences of error may be critical.

2.     Workers’ Entitlement

2.1  Eye Test

Any worker covered by the Regulations is entitled to request an eye and eyesight test which will be paid for by the employer.  Workers should inform their line manager, who will provide them with the forms to take to an option of the worker’s choice.

A worker may request a test if he/she:

o   Is already a user for a significant part of his/her work

o   Is about to start using display screen equipment for a significant part of his/her work

o   Is experiencing visual difficulties which may reasonably be considered to be related to display screen work

o   It is recommended by an option at the time of an eye examination that the worker should have eye tests at regular intervals

2.2  Spectacles

If as a result of the eye test a worker requires spectacles solely for use with display screen equipment, he/she is entitled to reimbursement of the cost of a basic pair.  If the worker wishes to choose more costly spectacles (e.g. a more expensive frame), the employer is not obliged to pay the full cost of these.  In this event the worker will only be reimbursed for the cost of basic spectacles.

If as a result of the tests spectacles are required for normal use, e.g. reading or distance vision, but which may also include display screen equipment use, under the Regulations the employer is not required to make reimbursement beyond the cost of the eyesight test and the report.

2.3  Who pays the Optician?

The worker pays the option and then obtains the reimbursement, attaching the receipt(s) and any report to the form DSE1, and gives these to his/her Line Manager who will arrange reimbursement.

ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

1. Introduction

Lamhan is committed to keeping the highest standards of ethics and integrity in all aspects of its operations, including the training services it offers. We strictly prohibit bribery, corruption, or any form of unethical behaviour in our business practices. This policy outlines our commitment to compliance with applicable anti-bribery and anti-corruption laws and provides guidance for employees, contractors, and partners associated with Lamhan’s training programs.

2. Scope

This policy applies to all employees, contractors, consultants, agents, and any other representatives of Lamhan. It extends to all interactions with clients, trainees, government officials, business partners, and other stakeholders involved in the training services provided by Lamhan.

3. Definition of Bribery and Corruption

   •       Bribery: The offering, giving, receiving, or soliciting of any item of value as a means of influencing the actions of an individual or organization in charge of a public or private duty.

   •       Corruption: Any dishonest or fraudulent conduct by those in power, typically involving bribery.

Examples of prohibited activities include:

   •       Offering or accepting payments or incentives to secure training contracts or attendance.

   •       Providing gifts, hospitality, or entertainment to influence decision-making related to Lamhan’s training programs.

   •       Facilitating payments to expedite administrative processes related to training arrangements.

4. Policy Statement

Lamhan will:

   •       Comply with all applicable anti-bribery and anti-corruption laws and regulations, including but not limited to the UK Bribery Act 2010.

   •       Prohibit the offering, giving, soliciting, or receiving of bribes or improper advantages in any form.

   •       Conduct all training-related activities with transparency and integrity.

   •       Maintain accurate and transparent records of all transactions related to training services.

5. Training and Awareness

Lamhan will provide regular anti-bribery and anti-corruption training to all employees and relevant stakeholders involved in its training services. This training will ensure:

   •       Awareness of Lamhan’s zero-tolerance approach to bribery and corruption.

   •       Understanding of applicable laws, potential risks, and how to avoid unethical practices.

   •       Clarity on reporting procedures for suspected violations.

6. Gifts and Hospitality

Lamhan acknowledges that gifts and hospitality may be customary in some business interactions. However:

   •       Any gift or hospitality must be modest, transparent, and not intended to influence decision-making.

   •       Employees must seek prior approval for any gifts or hospitality offered or received in connection with training activities.

   •       Lavish or inappropriate gifts, cash payments, or excessive hospitality are strictly prohibited.

7. Third-Party Conduct

Lamhan requires all third parties acting on its behalf, including contractors and agents involved in training services, to comply with this policy. Due diligence will be conducted on third parties to ensure they uphold Lamhan’s standards for ethical conduct.

8. Reporting and Whistleblowing

Employees and stakeholders are encouraged to report any suspicions or incidents of bribery or corruption. Reports can be made confidentially and without fear of retaliation. Suspected violations can be reported to Jo Watson, CEO, via email to hello@lamhan.org.uk

9. Disciplinary Action

Any breach of this policy will be treated as a serious matter. Disciplinary actions, including termination of employment or contracts, may be taken against individuals or entities found to be involved in bribery or corruption.

10. Monitoring and Review

Lamhan will regularly review and update this policy to ensure its effectiveness and compliance with applicable laws. Internal audits and risk assessments will be conducted to monitor adherence to this policy.

11. Conclusion

Lamhan’s commitment to ethical business practices underpins all its training services. By adhering to this anti-bribery and anti-corruption policy, Lamhan aims to foster trust, maintain its reputation, and contribute to a fair and transparent business environment.

Approval and Acknowledgment

This policy has been approved by Lamhan’s management team and is effective as of 19th November 2024. All employees and stakeholders are required to read, understand, and comply with this policy.

Anti- money laundering (AML)statement

At Làmhan, we are committed to upholding the highest standards of integrity and transparency in all our business operations. We take a zero-tolerance approach to money laundering and fully comply with all applicable anti-money laundering (AML) laws and regulations.

Our Commitment

Làmhan actively works to prevent any activities that facilitate money laundering or the financing of illegal activities. We have implemented robust policies and procedures to identify, mitigate, and manage risks associated with money laundering, ensuring compliance with applicable laws such as the UK Money Laundering Regulations 2017 and similar global standards.

Key Measures

To safeguard our operations and stakeholders, Làmhan has established the following measures:

• Customer Due Diligence (CDD): We verify the identity of all clients, partners, and stakeholders through rigorous due diligence processes.

• Transaction Monitoring: We maintain systems to monitor transactions for any unusual or suspicious activity.

• Record-Keeping: Làmhan retains accurate records of all financial transactions in compliance with regulatory requirements.

• Reporting Suspicious Activities: Any suspicious transactions or activities are promptly reported to the relevant authorities, such as the UK Financial Intelligence Unit (UKFIU).

• Staff Training: Our team receives regular training to identify and report money laundering risks and ensure compliance with AML obligations.

Zero-Tolerance Policy

Làmhan strictly prohibits any business relationship or transaction that involves illicit activities or violates AML regulations. Any violation of our policies will result in immediate action, including termination of relationships and reporting to authorities.

Contact Us

If you have any questions about Làmhan’s AML policies or wish to report concerns, please contact us at hello@lamhan.org.uk

By working together to combat money laundering, Làmhan is committed to promoting ethical practices and maintaining a transparent business environment for all.