MODERN SLAVERY STATEMENT

POLICY STATEMENT

Statement under Section 54(1) of the UK Modern Slavery Act 2015 for JB International Training Ltd (JBI)

1. Introduction

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 have a zero-tolerance approach and are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing procedures to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

2. Structure of the organisation

JBI provides learning and education services and technical skills courses to public and private sector clients at training centres throughout the UK

In order to provide services to clients, we work with a range of suppliers including but not limited to professional service firms, utility suppliers, IT vendors, consultants, industry business partners and technology platform providers.

3. Policies

As part of our commitment to combating modern slavery, we have implemented the following policies and procedures:

1. Anti-Slavery Policy

2. Supplier Decision Tree Matrix

3. Supplier Questionnaires

4. Whistleblowing Policy

5. Corporate Social Responsibility Policy

We also make sure our suppliers are aware of our policies and adhere to the same high standards.

These policies have been developed by our legal, HR, finance and IT teams.

4. Due diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have adopted the following due diligence procedures:

1. Suppliers must fill out questionnaires which elicit responses on their legal compliance with all applicable legislation;

2. Standard contractual language regarding a supplier’s compliance with all applicable legislation;

3. If necessary, periodic audits on certain suppliers to ensure compliance.

 

Our procedures are designed to:

• establish and assess areas of potential risk in our business and supply chains;

• monitor potential risk areas in our business and supply chains;

• reduce the risk of slavery and human trafficking occurring in our business and

supply chains; and

• provide adequate protection for whistle-blowers.

5. Risk and compliance

We do not consider that we operate in high-risk sectors or locations because of the nature of the services we provide and the location and composition of our suppliers.

We ensure all our suppliers adhere to our Anti-Slavery Policy. We enforce a strict code of compliance and do not tolerate slavery and human trafficking within our supply chains. For example, if we find evidence of a failure to comply with our policies which contain or reflect anti-slavery measures, we will immediately seek to terminate our relationship with the relevant supplier.

6. Training

We are raising awareness and continually taking time to invest in educating our staff  in order to recognise the risks of modern slavery and human trafficking in our business and supply chains. We have made good progress in this area, rolling out training and this will be repeated for all staff annually (with necessary updates) to ensure we remain vigilant.

7. Further actions and sign-off

Following our review of our actions this financial year to prevent slavery or human trafficking from occurring in our business or supply chains, we intend to take the following further steps to tackle slavery and human trafficking: (i) new training videos and instructions for employees and (ii) an updated Anti-Slavery Policy.

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes the JBI’s slavery and human trafficking statement for the financial year ended 31 March 2024.

This statement was approved by JBI’s Managing Director.

Dated : 1 January 2024

Signed

Jonathan Bambaji

Managing Director

JB International Training Ltd

INCLUSION & EQUALITY POLICY (01 January 2024)

We at JBI recognise that discrimination is unacceptable and although equality of opportunity has been a long standing feature of our employment practices and procedure, we have made the decision to adopt a formal equal opportunities policy. Breaches of the policy will lead to disciplinary proceedings and, if appropriate, disciplinary action.

The aim of the policy is to ensure no job applicant, employee or worker is discriminated against either directly or indirectly on the grounds of race, colour, ethnic or national origin, religious belief, sex, marital status, sexual orientation, gender reassignment, age or disability.

We will ensure that the policy is circulated to any agencies responsible for our recruitment and a copy of the policy will be made available for all employees and made known to all applicants for employment.

The policy will be communicated to all private contractors reminding them of their responsibilities towards the equality of opportunity.

The policy will be implemented in accordance with the appropriate statutory requirements and full account will be taken of all available guidance and in particular any relevant Codes of Practice.

We will maintain a neutral working environment in which no employee or worker feels under threat or intimidated.

ETHICAL POLICY (Date 01 January 2024)

We at JBI recognise and accept that the activities involved in running the business necessarily impinge upon the environment, the workforce and out business associates.

We therefore would like to commit to ethical trading, which means that we will adhere to the following principles :

• Working conditions are safe;
• Good health is promoted;
• Employment is freely chosen;
• Working hours are not excessive;
• Wages meet at least national legal standards;
• Training is provided;
• No discrimination is practised;
• Diversity and good workforce practices are encouraged;
• Child labour is eliminated;
• Sub-contractors are treated fairly;
• Suppliers and sub-contractors are paid promptly;
• No inhumane treatment is allowed;
• Bribary & corruption will not be facilitated or tolerated in our business;
• Tax evasion and Money Laundering will not be facilitated through our business dealings

ENVIRONMENTAL POLICY (Date 01 January 2024)

We at JBI recognise and accept that the activities involved in running the business necessarily impinge upon the environment.

In an effort to minimise these effects, we are committed to a policy of sound and responsible environmental management, leading to a sustainable use of resources and optimal management of waste.

As such we will:

• Ensure that all employees at all levels are aware of the potential environmental effects of their activities and the  benefits of improved environmental performance, and will provide specific environmental training to this effect.
• Communicate this environmental policy and promote environmental awareness amongst all employees.
• Ensure that all employees are instructed on the potential environmental effects of their activities and the benefits of improved environmental performance.
• Display this policy statement in a prominent position within the offices
• Make this policy statement available to all interested parties on request.
• Comply with all applicable environmental legislation as a minimum standard.
• Promote the principle of ‘sustainable development’ whereby the present needs of the JBI will not compromise the  abilities of future generations to meet their own needs.
• Adopt a policy of ‘green procurement’, taking environmental factors into account in all purchasing and supplier contracts.
• Provide organic produce where available and never knowingly use genetically modified ingredients or products;
• Take all measures that are reasonably practicable to:

           1. Reduce waste at source;
           2. Re-use waste components where it is safe and practicable to do so;
           3. Recover/recycle those fractions of the waste stream where an outlet is available; and dispose of final wastes  by the most environmentally suitable means;
           4. Reduce wherever possible use of plastic bottles, bags, etc
           5. Adopt the practice of responsible energy management through reduced consumption and the   encouragement of energy efficiency throughout the business;
           6. Encourage the use of public transport and the provide facilities for the disabled, pedestrians and cyclists; and   aim for continuous improvement.

Dated : 1 January 2024

Signed

Jonathan Bambaji

Managing Director

JB International Training Ltd

 

BUSINESS CONTINUITY PLANNING STATEMENT (01 January 2024)

JBI Training maintains important disaster recovery and business continuity plans that may be activated in the event of a significant business disruption. The firm realizes the critical nature of being able to continue material operations if an incident occurs that could affect mission-critical business units and systems. These plans are key components in maintaining emergency procedures, and are required by securities industry regulations.

In planning for potential significant business disruptions, JBI Training has considered a number of outcomes from varying scenarios, including, as examples only, a disruption to a single building, a city-wide business disruption and a regional disruption. The firm’s plans are intended to permit the continuation of key business operations during most types of disruptions by resuming mission-critical operations, usually within the same business day as the disruption. To assist this business continuity the firm maintains back up capabilities in alternative locations. In cases of an extreme disruption, where the continuation of business may not be practical or in the best interest of the firm or its clients, JBI Training has implemented steps necessary to allow clients prompt access to their funds and securities.

However, clients should be aware that because the firm’s plans contain details of a confidential and proprietary nature, they cannot be distributed to the public. Clients should also note that JBI Training’s business continuity plan is subject to modification, and that updated summaries of the plan will be promptly posted on the JBI Training website, as permitted by applicable law.

Dated : 1 January 2024

Signed

Jonathan Bambaji

Managing Director

JB International Training Ltd

 

HEALTH & SAFETY POLICY (Date 01 January 2024)

POLICY STATEMENT

JB International Training Ltd ("JBI", "we", "our" or "us") 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 visitors to its premises under the Health and Safety at Work Act 1974, the Fire Precautions (Workplace) Regulations 1997, the Management of Health and Safety at Work Regulations 1999, 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 JBI to promote the health and safety of the committee members, volunteers, staff and of all visitors to our 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 JBI 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 JBI’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 Groups/Organisation arising out of or in connection with JBI’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 JBI’s premises may be exposed.

• Follow Government health guidance and allow staff paid time off to receive health advice, tests and medical treatment (including vaccinations). Encourage staff to get vaccinated in line with Government advice in order to help protect themselves, colleagues, business associates, clients and others sharing the working environment and in order to limit absences from work (regardless of location) due to workers catching disease such as COVID-19 or being required to self-isolate.

Dated : 1 January 2024

Signed

Jonathan Bambaji

Managing Director

JB International Training Ltd

PRIVACY POLICY (Date 01 January 2024)

 

JB International Training Ltd ("JBI", "we", "our" or "us") are committed to ensuring that your privacy is protected. This Privacy Notice describes how we use the personal information that we collect from you, or that you provide, when you:

    visit any of our websites, portals or online learning environments (the "Website");
    use the educational services, testing, certification, products, and consultancy services (together the "Services") that we provide; or
    communicate with us.

Information We Collect

Information that you provide directly

We collect personal information from you:

    through the use of forms, which may be on paper or on our Websites, such as when you login to access our Services, signup to receive our newsletters, register for information, or make a purchase or commence a course of study;
    when you create an account on our Websites and provide us with information about any special requirements, such as dietary requirements, that you may have; and
    if you choose to provide us with information when you use our Website or access our Services;
    when you communicate with us for any reason, including by email, postal mail or telephone, and when you use our Services.

Some of the personal information that you provide may include sensitive personal information, such as health-related information or information about your race or ethnicity, which we need for statutory registration/reporting purposes and to ensure that we can provide the necessary duty of care.

Information that we collect automatically

When you visit our Website, we may collect certain information automatically from your device.

Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.

Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.

Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading 'Cookies', below.

Information that we obtain from third party sources

We may receive personal information about you from third party sources (such as your employer if they enroll you on a course, or agencies if you apply for study or employment, but only where we believe that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us. We collect only the minimum amount of information required from these third parties to enable us to provide the requested service or process any application you send to us (for example, your educational or employment history). We only use the information we receive from these third parties as set out in this Privacy Notice.

Use of Your Information

The information that we collect and store relating to you is primarily used to enable us to provide our Services to you. In addition, we may use the information for the following purposes:

    to provide you with information or Services you request from us;
    to provide information on other JBI products and Services which we feel may be of interest to you, in accordance with your communications and consent preferences;
    to meet our contractual commitments to you;
    to act on your behalf where third party involvement is available and appropriate – for example through a third party specialist training provider or certification/awarding body;
    to obtain additional personal information to secure funding or satisfy statutory legal or Government scheme requirements – for example through an Apprenticeship scheme;
    to monitor and analyze trends, usage and activities in connection with our Websites/Services; andas necessary to prevent or detect crime.

We may also monitor or record telephone calls for training, customer service and quality assurance purposes, and to detect or prevent crime, [and will inform you that we do so when you call us]. These recordings will be retained for a maximum of 30 days.

In general, we will use any of the information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect such information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as statistical purposes) if and where this is permitted by applicable data protection laws.

If you do not want us to use your data for any marketing purposes, you will have the opportunity to withhold your consent to this when you provide your details to us.

Consent can be varied by emailing us [email protected]

Storing and Retaining Your Personal Data

The personal information you provided to us is stored within secure servers. We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

All JBI email addresses support TLS email encryption, so it is advised that if you are concerned about the contents of any email to use this encryption.

Where we have given you (or where you have chosen) a password so that you can access certain parts of our sites and portals, you are responsible for keeping these passwords confidential.

Please note that the transmission of information via the internet (including email) is not completely secure and therefore, although we endeavor to protect the personal information you provide to us, we cannot guarantee the security of data sent to us electronically and the transmission of such data is therefore entirely at your own risk.We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business or statutory need to process your personal information, we will either delete or anonymise it.

Disclosing Your Information

We may disclose your personal information, with your consent, to any company within our corporate group. This includes, where applicable, our subsidiaries, our holding company and its subsidiaries.

We may also disclose your personal information with:

    third party service providers and partners who provide data processing services to us (for example, to support the delivery of Services), or who otherwise process personal information for purposes that are described in this Privacy Notice;
    third party funders, where required within Apprenticeships or further/higher education;
    your employer, where required within an Apprenticeship program/Higher Education program or other
    government agencies, where required by the scheme or education path you elect to follow;
    partners with whom we work to provide Services (such as course vendors, examination bodies and trainers);
    any third party in connection with, or during negotiations of, any merger, sales of company assets, financing or acquisition of all or a portion of our business by another company;
    any law enforcement agency, court, regulator, government authority or other third party where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party; and to
    any other person with your consent to the disclosure.

Where you are a customer or prospective customer, we may disclose your data to third parties for our marketing purposes so that we can identify products and services we think you will be interested in. Personal data used in this way may include contact details such as name, address, phone number, and email address. When sharing with third party marketing organisations, your data may be processed in countries inside or outside of the EU.

Third Party Links

You might find links to third party websites on our Websites or within documentation we provide.

If you access other websites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their own privacy policies which you should review.

We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.

Social Networking

The Website may offer you the opportunity to share or follow information about us (or the Website or our Services) using third party social networking functionality (such as through "share this", "like" or "follow" buttons).

We offer this functionality in order to generate interest in us, the Website and our Services among the members of your social networks, and to permit you to share and follow opinions, news and recommendations about us with your friends. However, you should be aware that sharing personal or non-personal information with a social network may result in that information being collected by the social network provider or result in that information being made publicly-available, including through Internet search engines.

Please note that we do not exercise, endorse or control the policies or practices of any third party social network whose functionality you may access through the Website.

You should always read the Privacy Notice of any social network through which you share information carefully in order to understand their specific privacy and information usage practices.

International Data Transfers

For some of our Services, your personal information may be transferred to, and processed in, countries outside of the EEA. However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice. These measures include transferring your personal data to third parties who are located in a country which the European Commission has determined has data protection laws that are at least as protective as those in Europe, and transferring your personal data to third parties who have entered into standard contractual clauses with us. For more information about these safeguards please contact us using the contact details provided below.

Cookies

We may use cookies and similar tracking technology (collectively, "Cookies") to collect and use personal information about you.

Legal Basis (EEA visitors only).

Our legal basis for collecting and using personal information will depend on the personal information being collected and the specific context in which we collect it.

However, we will normally collect personal information from you only:

    where we need the personal information to perform a contract with you (for example, to enroll you into a course or provide you with learning materials);
    where the processing is in our legitimate interests and is not overridden by your rights; or
    where we have your consent to do so;

In some cases, we may also have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our platform and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided below.

Data protection rights

You have the following data protection rights:

    If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided below.
    In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided below.
    You have the right to opt-out of marketing and telemarketing communications we send you at any time. You can exercise this right by clicking on the "Manage your Marketing Preferences" link in the marketing e-mails we send you and within our Websites.
    Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
    You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Contacting Us

The data controller of your personal information will be JBI

We welcome any queries, comments or requests you may have regarding this Privacy Notice. Please do not hesitate to contact us, or our DPO, via email at: [email protected]

Changes to the Privacy Notice

We may change this Privacy Notice from time to time by updating this document.

You should check this page from time to time to ensure that you are happy with any changes.

If material changes are made to this Privacy Notice, we will notify you by placing a prominent notice on the Website or by contacting you to let you know via the contact details you have provided us with.

Dated : 1 January 2024

Signed

Jonathan Bambaji

Managing Director

JB International Training Ltd

 

QUALITY STATEMENT (Date 01 January 2024)

 

Quality

A market survey showed that JBI’s clients perceive it to be a high quality, specialist training company.

Our focused range of courses means that we can concentrate on delivering the very highest quality courses in our specialist subject areas.

We achieve this by putting a hand-picked subject matter expert who can both engage the audience and add real value to their organisations with high quality training which is cutting edge, current and relevant.

Continuous improvement

JBI’s long term relationship with clients  is built on the commitment to provision of cutting edge courses and our ability to evolve those courses in line with client expectations.

Example of continuous dedication to changing software delivery and development

JBI were the first in the UK to offer basic JavaScript and Dynamic HTML courses in 1995 and since then JBI has evolved these courses through various iterations of the technology, culminating most recently with React 18.2 (at the time of writing) .

Measures for success

Prior to the course, JBI Instructors and client stakeholders will discuss the course objectives and desired outcomes. JBI will then propose a detailed course outline that delivers the desired outcomes. Discussions will include the following:

• Business objectives for the training

• Scope and list of technical topics to be covered

• Determining the order and weight of these topics with regards to priority

• Prerequisite delegate skills

• Course duration and delivery method

• Practical content and Labs

Course feedback

Following the completion of the training course, the individual delegates will be invited to provide feedback verbally and through online feedback forms. We invite delegates to rate the course out of 10 on : Overall impression, the instructor, presentation, content and structure, as well as providing space for more detailed written feedback on their likes and dislikes of the course and any improvements they would have made.

Post Course action

Feedback will be reviewed by the account managers and a list of issues will be drawn up. Issues will be discussed internally and with the instructor to analyse root causes and suggest action points to improve. Issues will be discussed and action points agreed with the client with a view to implementing changes prior to any further runs of a course.

JBI is always looking to seek honest feedback from the delegates to help improve quality.

Risks and Assumption

Technology courses are complex and constantly evolve. The risk to the client is that communications pre and post course are poor and objectives are misunderstood.

We also prefer that delegates possess any agreed prerequisite skills for the training.

Early stakeholder involvement in course definition and actioning course feedback will mitigate these risks.

 

 

GRIEVANCE POLICY

Part I: Policy details

What does this policy cover and who is covered?

JB International Training Ltd (JBI) endeavours to ensure that our employees are happy working for us. An important part of that commitment includes putting in place a policy to ensure that we promptly, fairly and consistently address any complaints, concerns, and problems relating to your employment with us.

Complaints about matters not concerning your employment, such as the behaviour of other workers towards you, or about the way that unlawful, unethical or inappropriate behaviour within, or affecting JB International Training Ltd, should be raised under our other policies for Bullying and Harassment, or Whistleblowing.

If someone makes a complaint against you, under this or any of our other policies, we will apply our Disciplinary Policy and/or Performance Improvement Policy if appropriate.

Who does it apply to?

All employees.

It is not part of your employment contract

This policy is not part of your employment contract. We, JB International Training Ltd, may amend this policy at any time.

Your right to be accompanied at grievance meetings

During any meeting that takes place under this policy, you may bring someone with you (normally referred to as a companion). That person is generally a colleague, a work colleague, or, if appropriate, a trade union representative.

We will remind you of this entitlement when we send you a meeting invite. You must then let us know if you intend to invite someone to accompany you and who that person is, as well as their relationship to you, if this is not known to us. You will be responsible for them attending the meeting, including making (if necessary), any travel arrangements and costs.

You are entirely free to choose a work colleague to accompany you. If you do choose a work colleague, please be aware that, on occasion, we may need to adjust scheduled meeting timings to ensure that we can ensure your colleague’s attendance (and absence from their usual work duties) does not cause any operational challenges.

Speaking on your behalf

If you would prefer them to do so, your companion may present the key points of your grievance and may also speak openly on your behalf at the meeting. You should feel free to seek their views and confer with the during the meeting and you are entitled to leave the room for a reasonable period of time to do so.

Your companion is not permitted, however, to answer questions put directly to you or try to prevent the Company asking you questions or outlining its views.

Part II: Our procedure for raising a grievance

Please follow this procedure. It is designed to ensure fair and efficient handling of any complaint or concern raised by JBI’s employees.

Before formal action is taken: If you have a concern

We strongly encourage you to approach the Managing Director if you are concerned or unhappy about any problems or issues with your employment. We believe that an informal discussion can often be the most effective and rapid means to resolve most concerns that employees raise. Your Managing Director understands that they are expected to help address any such concerns in line with our policies and our business values.

If this discussion is not successful in resolving your concern, you must follow the procedure below.

 

Stage 1: formal grievance action – reporting and gathering the facts

1. Provide written details of your complaint to the Managing Director. Make sure that you include:

   • What has happened

   • The names of any individuals involved

   • The history and any relevant dates (at least approximate ones) relating to all of the facts you describe

   • Any materials (correspondence, screenshots of communications, etc.) that help to support what you have described

   • What steps you have already taken to resolve your concern(s) (including whether you have already spoken with the Managing Director) and the outcome of those steps.

   • What action you want JBI to take in response to your complaint, and what outcome you would like. For example, you might request that a particular policy, procedure, practice or set-up within our business is changed; or perhaps that a warning be issued to a particular individual to whom your complaint might relate.

2. You should also clearly state within this written document that you intend for it to be handled under JBI’s formal grievance procedure.

3. We will acknowledge receipt of your grievance (in writing within 3 days) and tell you how we intend to deal with it, the precise nature of which may depend on what you have told us.

4. We will thoroughly examine all relevant facts and materials available to us and you will be required to co-operate with us so that we can ensure a fair and thorough investigation into the issue(s) you have raised. As soon as we have completed our investigation, we may ask you to attend a formal interview and/or take a formal statement from you about the matter. We may also ask other people to attend interviews and/or provide statements too.

5. We will do our best to give you a timeframe of how long the investigations may take, if they cannot be completed within 7 days.

Stage 2: formal grievance action – the grievance meeting(s)

1. We will hold a formal meeting and invite you to attend. At this meeting, we will ask you to explain your concern(s) and how you think we should resolve it/them. It is an important part of our formal grievance process.

2. The meeting will usually take place within 5 working days of you lodging your grievance. We ask that you make every effort to attend it. If you are unable to attend, we will make all reasonable efforts to reschedule the meeting to an alternative time that you are able to make.

3. If you wish to do so, you may bring someone with you to the meeting. You are free to determine who that person might be. Ordinarily, it will be a work colleague or a relevant trade union representative, for example, as you prefer. (See Part I, paragraph 4 – “Speaking on your behalf”)

4. We will not record this meeting without your knowledge. Please do not record the meeting without our knowledge and consent. If at any time, you have concerns about our grievance process or the individual(s) leading it on our behalf, you should tell us promptly and openly, so that we can address your concerns.

   OR

   We may record this meeting, but we will not do so without telling you. You may of course record the meeting if you wish to do so; but please tell us and agree it with us beforehand if you intend to do so, as it would be discourteous and potentially unlawful to make a covert recording.

5. Once the above meeting has been held, we will often need to further investigate the matters discussed. That may involve further locating and considering relevant documentation and speaking with other people, whom we may wish to formally interview or re-interview. It is not generally permitted for you to participate in these activities, including to ask direct questions of other people during an interview. But we will keep you informed of progress and we may well ask you for more information of for another meeting. It is also possible that we will not consider there to be a need for further meetings or follow-up after the above meeting.

Stage 3: formal grievance action – JB International Training Ltd’s decision

Within a week of the final meeting that we decide to hold with you during this stage, we will provide you with a written decision, outlining our conclusions and how we have decided to address your grievance.

Stage 4: formal grievance action – your right to appeal

1. If you are not happy with our decision, you are entitled to appeal it. You must do so in writing within one week of receiving our decision.
2. Your appeal must be set out in writing and:
   • Addressed to the relevant person identified as the correct recipient for an appeal in our written decision
   • Clearly set out why you are appealing against our decision
   • Provide any new information or evidence on which you wish to rely since our earlier investigations were completed

Stage 5: formal grievance action – the appeal hearing

Usually within two weeks of you notifying us of your appeal, we will invite you to attend a further meeting with us. As before, you are entitled to ask someone to accompany you.

Stage 6: formal grievance action – JB International Training Ltd’s final decision

1. Following this meeting, we will provide you with our written, final decision. We aim, wherever we can, for you to receive this decision within two weeks of the appeal hearing.
2. This concludes our process. We do not consider any further appeals.

 

DISCIPLINARY PROCEDURE / POLICY

Part I: Policy details

What does this policy cover and who is covered?

This policy covers JB International Training Ltd's (JBI’s) procedure when a disciplinary matter arises, usually where there is reasonable concern or suspicion that an employee has engaged in one or more actions that can be classified as ‘misconduct’.

Although this is not an exhaustive list, we tend to treat ‘misconduct’ as comprising one or more of the following activities:

• Minor breaches of our policies

• Minor breaches of your employment contract

• Unauthorised use, or damage to, our property and equipment

• Absence from work that has not been authorised

• Poor attendance and timekeeping

• Refusing to follow instructions, where it is not serious enough to be gross misconduct

• Misuse of the internet or your work email for personal purposes, including sending and receiving an excessive number of personal emails

• Misuse of JBI's devices or JBI's communication accounts, including making an excessive number of personal calls using JBI's phones

• Behaving offensively, including making lewd gestures and using obscene language (verbally or otherwise)

• Being careless in the performance of your work duties

• Time-wasting during your contracted working hours

• Smoking where smoking is not allowed

By contrast, and again, not an exhaustive list, we treat ‘gross misconduct’ as typically comprising one or more of the following activities:

• Malicious misuse of any of our procedures, for example if you make up allegations when taking out a grievance against someone

• Negligence, recklessness or carelessness, particularly if it leads to JBI and its management losing trust and confidence in you

• Serious breach of all data privacy and data protection legislation applicable to our business

• Serious health and safety breaches including not following Government health advice (including vaccinations advice and responsibilites/behaviour during pandemic and other major health events)

• Unlawful harassment or discrimination

• Viewing, receiving, or sending anything that breaches JBI's Harassment and Bullying Policy or our Equal Opportunities Policy

• Bullying or physical violence

• Fraud, theft, or any act of dishonesty

• Being under the influence of, or possessing, illegal drugs

• Being under the influence of alcohol, unless this is with your manager’s express knowledge and permission – for example, where you are involved in entertaining on the Company’s behalf

• Serious and intentional damage to Company property

• Knowingly accessing websites containing offensive, obscene or pornographic material

• Serious insubordination or refusal to obey management instructions

• Serious breaches of confidence (such as disclosing JBI's confidential information without authorisation and/or putting JBI's IP or trade secrets at risk)

• Conduct that breaches common decency or brings the Company into disrepute

 

Part III of our guide sets out our approach in relation to gross misconduct, which is not the same as the way in which we handle allegations of misconduct.

There’s a third category of misconduct that falls inbetween these two: ‘serious misconduct’. We define this as misconduct that falls short of gross misconduct but that, taken with any previous and non-expired written warning(s) on an employee’s record, would justify the imposition of a final written warning. (We cover this in context at Part II, Stage 3 of the formal disciplinary process, below.)

We will normally follow this policy in a disciplinary situation, but we are not obliged to do so (particularly if you are in your probationary period).

Who does it apply to?

All employees. It does not apply to self-employed contractors, workers and agency workers.

It is not part of your employment contract

This policy is not part of your employment contract. We, JBI, may amend this policy at any time.

Your right to be accompanied at disciplinary meetings

During any meeting that takes place under this policy, you may bring someone with you. That person is generally a colleague or, if relevant, a trade union representative.

We will remind you of this entitlement when we send you a meeting invite. You must then let us know if you intend to invite someone to accompany you and who that person is, as well as their relationship to you if this is not known to us. You will be responsible for making their attendance (including any travel) arrangements and costs.

You are entirely free to choose a work colleague to accompany you. If you do choose a work colleague, please be aware that, on occasion, we may need to adjust scheduled meeting timings to ensure that we can ensure your colleague’s attendance (and absence from their usual work duties) does not cause any operational challenges.

Speaking on your behalf

If you would prefer them to do so, your companion may present the key points of your grievance and they may also speak openly on your behalf at the meeting. You should feel free to seek their views and confer with the during the meeting and you are entitled to leave the room for reasonable periods of time to do so.

Your companion is not permitted, however, to answer questions put directly to you or try to prevent the Company asking questions or outlining its views.

 

Part II: Our procedure when disciplinary matters arise

This sets out the steps that we take when a disciplinary concern first arises, with the exception of where an allegation of gross misconduct arises. (Please see Part III of this policy for information on our approach where gross misconduct has been identified.)

Before formal action is taken: informal discussions, communications and resolutions

Where we feel it’s appropriate to do so, we will communicate with you either verbally or in writing to formally highlight any concerns that we have with your conduct or performance. We will then aim to chat through any such concerns with you, including where this raises a disciplinary element. Following that chat, we may send you a communication (sometimes known as a Letter Of Concern), recording what we have discussed during that informal meeting and, if possible, suggesting a resolution.

If we can’t resolve matters during this chat or subsequent communications, or we consider that the circumstances in which our concerns have arisen make an informal discussion inappropriate, we will typically follow the formal procedure described below.

 

Stage 1a: formal disciplinary action – formal meeting

1. We will not take disciplinary action without first having invited you to a formal meeting to discuss the concerns that have been identified. This may, however, be the only meeting that we invite you to. You may not be invited to attend any subsequent meetings that take place during any investigatory or disciplinary decision-making stages.

2. We will write to you to invite you to this formal meeting and to provide you with the key details that you need to know, including when and where the meeting will take place, details of misconduct allegations that you may face, and the potential ramifications of these allegations being proven, or not. Unless we believe there is a good reason not to do so, we will also provide you with copies of any documents relevant to the facts, and any witness statements that we have taken.

3. Your attendance at this meeting is really important and you’re responsible for ensuring that you can make it. We will usually agree to reschedule the meeting once if, for good reason, you are unable to make the first time that we propose. But we will not allow interactions about when you can make this meeting to unreasonably delay it. If after rescheduling it once, we remain unable to schedule your attendance at this meeting, and we do not consider that your requests for other times are reasonably made, we may be forced to proceed without you being present.

4. You are entitled to be accompanied at the meeting. See Part 1 section 4 for the rules on how this works.

5. If you want to bring your own witnesses to the meeting and/or you have documents or other evidence you want to present, you must let us know as soon as possible in advance of the meeting taking place.

6. During the meeting, we will go through all the details of the allegations against you, and we will outline the information, documentation and witness statements that comprise the evidence we have. We will ask you to confirm that you understand all that we have presented to you and you will be given sufficient opportunity to respond and to ask questions of us, as well as to put forward your own evidence for us to further consider. You may also invite your own witnesses to speak on your behalf at this meeting. If you want to ask questions of our witnesses, please let us know in advance and (unless we believe there is good reason not to) we will ensure that they are asked those questions, respond and that we share their responses with you in a suitable manner.

7. We will not record this meeting without your knowledge. You are not permitted to record the meeting without our knowledge and consent. If at any time, you have concerns about our process or the individual(s) leading it on our behalf, you should tell us promptly and openly, so that we can address your concerns.

OR

We may record this meeting, but we will not do so without telling you. You may of course record the meeting if you wish to do so; but please tell us beforehand and agree it with us if you intend to do so, as it would be discourteous and potentially unlawful to make a covert recording.

 

Stage 1b: formal disciplinary action – suspension for misconduct

(For how we handle gross misconduct, please see Part III of this policy.)

It is possible that we may suspend you from work, if you’re accused of misconduct. This is not a prejudgment of any decision that we may ultimately reach – we will not have made any decisions at this stage. Suspension is typically driven by the disciplinary concerns that have been raised, the need to carry out a fair and unhindered investigation and all the factors that we have so far considered. So, if we suspend you, it will be in order to cause the least disruption to the business while we investigate.

If you are suspended from work, the following factors will apply:

1. You will be prohibited from coming in to your normal workplace, or any other premises from which we conduct our business

2. Unless we give you written authorisation to do so, you must not contact any staff, clients, customers or suppliers – unless your need to contact a particular individual arises from your intention to request them to act as a witness for you (in which case, you do need to inform us first)

3. Provided that your contract terms do not contradict this, we will continue to pay you your full entitlement. If you fall sick during this suspension period and are unfit to work, you will be paid according to our Sickness Policy, which might mean you do not receive your full pay (i.e. if you are only entitled to statutory sick pay under your contract terms)

4. If pre-approved holidays fall during a period of suspension, they will still count as holiday leave and will be deducted from your holiday entitlement as normal

 

Stage 1c: formal disciplinary action – if you raise a grievance

Our disciplinary process will usually continue uninterrupted, even where you may raise a grievance while we are conducting our disciplinary investigation. If your grievance is linked to the matters that we’re investigating under the disciplinary process, we will normally consider the matters you raise as part of the disciplinary process and not start a separate grievance process.

Stage 2: formal disciplinary action – JBI's decision

Normally within 2 weeks of the formal meeting, we will provide you with JBI's written decision, outlining our conclusions and what we have decided.

Stage 3: formal disciplinary action – disciplinary action and our dismissal process

Where our decision identifies misconduct by you, we generally take the approach set out immediately below. If we have identified gross misconduct by you, our approach is different. Please see Part III of this policy for how we handle gross misconduct.

1. Step 1:

You will receive a written warning from us, which will normally remain on your work record for 12 months from the date you receive our decision. It will then be removed from your record.

The only exceptions to this position will be if:

1. you already have one or more non-expired written warnings on your work record, or

2. your misconduct was serious (but not gross) misconduct.

in which case, we will move straight to Step 2 below. (And in the case of gross misconduct, see Part III below.)

2. Step 2:

Where one (or both) of the exceptions in Step 1 have been met, we will issue you with a final written warning that will also go on to your work record alongside any existing, still active, written warning(s).

That final written warning will also stay ‘active’ on your work record and only expire 12 months from the date that you receive our written decision. After that 12-month period, it will be removed.

3. Step 3:

If Step 2 has already been met and you are involved in further misconduct, you may be dismissed.

You may also be dismissed for a serious case of misconduct, or if you are involved in gross misconduct.

Occasionally at this point, although we are not obliged to do so, we may be prepared to consider other actions besides your dismissal. This might include, for example:

1. extending your final written warning period, to provide additional time for you to convince us that your behaviour can reliably be improved,

2. moving you into a different role within our business, or

3. demoting you from your current position.

Either of the actions at (ii) or (iii) above can result in reduced pay to you.

Stage 4: formal disciplinary action – appeals

You are entitled to appeal against any of the decisions we take under this process. If you want to appeal, you must:

1. Write to us within a week of receiving our decision. You should address your letter to the person whom we will have identified in our decision communication and you will need to give clear grounds for why you are appealing the decision.

2. Once we have received your appeal letter, we will invite you to an appeal meeting. We will aim to hold this appeal meeting within 2–3 weeks of receiving your appeal letter.

3. Wherever we can reasonably organise this, the appeal meeting will be led by someone other than the person who led and made decisions relating to earlier disciplinary meetings about this instance of misconduct.

4. You are entitled to invite someone to accompany you at this meeting. (The rules outlined in Part I, section 4, apply here.)

 

Stage 5: formal disciplinary action – final decision, after an appeal

Our final decision will be sent to you in writing, normally within 2 weeks of the appeal meeting.

You do not have any further right to appeal against our decision.

Part III: How we handle cases of gross misconduct

You will usually be dismissed without warning, without notice, and without payment in lieu of notice, if we find you have committed an act of gross misconduct.

This is known as summary dismissal.

You have the same rights of appeal as set out above in our misconduct process (see Part II above)

Part III: How we handle cases of gross misconduct

You will usually be dismissed without warning, without notice, and without payment in lieu of notice, if we find you have committed an act of gross misconduct.

This is known as summary dismissal.

You have the same rights of appeal as set out above in our misconduct process (see Part II above).

SICKNESS ABSENCE PROCEDURE/POLICY