Business Gifts

What this policy covers

This policy applies to employees, workers and contractors.

The acceptance of gifts and offers of hospitality can give rise to suspicion of inappropriate conduct, particularly if offered by individuals or businesses that carry out, or are hoping to carry out, business for the Company.

This policy establishes the fundamental principles of the giving, accepting and refusing of gifts and hospitality.

Your responsibilities

Hospitality

You must not accept offers of hospitality, including attending sporting and social functions, unless these are properly authorised and recorded by the appropriate manager.

Acceptance of hospitality at relevant conferences, courses or events may be appropriate where it is clear that the hospitality is corporate rather than personal and where the Company has given its consent in advance.

All associated benefits, such as accommodation, travel, entertainment, and presents must be refused.

Gifts

As a general rule, you should not accept gifts from suppliers, clients, customers, contractors or any other person you deal with in your role with the Company.

If the value of the item is negligible, or if the item is presented as a seasonal gift, you should comply with the procedure set out below.

Procedure

Hospitality

When hospitality is declined, those making the offer should be politely informed of the Company's policy and procedures for accepting such offers.

Receipt of gifts

If the gift might constitute a bribe or other inducement, you are required to give the gift to your line manager, who will return it to the donor with a suitable covering letter.

In other instances, where appropriate, the Company will require you to return the gift to the donor with a polite note explaining the Company policy.

In exceptional cases, for example, if the Company decides that the gift was made as a token of the donor's gratitude for a service carried out the Company may allow you to retain the gift.

Promotional gifts that are of trivial value (for example, promotional pens) are exempt from this policy and need not be disclosed.

On seasonal occasions you may receive a number of gifts, for example, chocolates, bottles of wine, and so on. These gifts should be given to your line manager, who will ensure that they are distributed appropriately across the Company.

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.

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

Environmental responsibility

Electro South West Ltd is fully committed to managing and improving its environmental performance, by assessing all our operations and products to gauge their impact on the environment. We implement measures to minimise or eliminate negative impacts and strengthen positive effects. An environmental management system is used to help achieve and ensure we comply with environmental regulations. Electro South West Ltd engages with its suppliers, where appropriate, to assist in continually improving our environmental performance and reduce our total impact, for example by maximising recycling and improving energy efficiency.

Social and ethical responsibility

Electro South West Ltd attaches great importance to its role as a corporate citizen. It seeks to meet the highest standards of social, ethical and employment practice. Electro South West Ltd follows this code of conduct and challenges its suppliers to adopt similar principles. This applies to all direct suppliers, as well as their sub-contractors, to observe best practice in the following areas: general employment practices, the employment of appropriate workers, worker insurance, working environment, respect for the individual worker; and equal opportunities.

Diversity and equal opportunities

Electro South West Ltd is committed to Diversity and Equal Opportunities for all, irrespective of colour, race, religious belief, ethnic or national origins, gender, marital status, sexual orientation, disability or age. The Electro South West Ltd approach for the provision of goods and services is to look to build business relationships with those suppliers who support and apply similar principles.

Electro South West Ltd Counterfeit Goods Statement

Objective:

To prevent the introduction of counterfeit or substandard product into our ranges through strict adherence to correct procurement and purchasing procedures.

Purchase of product:

The presence of counterfeit product in the international supply chain is a growing concern for distributors and customers alike as low-cost alternatives to traditional sources become available.

Electro South West Ltd is fully committed to obtaining only products of the highest quality for our customers. We maintain an ISO9001:2015 management system which ensures all our suppliers agree to provide products solely from reputable sources.

All our suppliers understand that if any counterfeit products are introduced due to their negligence then action will be taken by Electro South West Ltd to suspend any further purchases until that supplier or suppliers can guarantee to conform to the required ISO standard.

Reporting:

Electro South West Ltd reports all incidents of counterfeit parts to internal organisations, other manufacturers and to customers

Issue 02

Dated; 04th January 2018

Electro South West Ltd is fully committed to the achievement of sound environmental performance via the minimisation of our environmental impacts. In order to attain this objective the company shall;

• Commit to the protection of the environment and the prevention of pollution in order to reduce adverse environmental impacts.
• Ensure compliance with applicable compliance obligations.
• Establish policies and objectives for the continual improvement of the management system to enhance our environmental performance.
• Ensure this environmental policy is implemented, maintained, reviewed and is communicated to all persons working for or on behalf of the company.
• Ensure this policy is available to interested parties.

Issue 02

Dated; 05th January 2021

Electro South West Ltd is fully committed to the prevention of injury and ill health via the elimination of hazards and minimisation of risks. In order to attain these objectives the company shall;

• Commit to the prevention of injury and ill health.
• Ensure compliance with applicable legal and other requirements.
• Commit to the consultation of and participation with staff.
• Pursue continual improvement from an objective evaluation of our occupational health and safety performance.
• Ensure this health and safety policy is implemented, maintained, reviewed and is communicated to all persons working for or under the control of the company.
• Ensure this policy is available to interested parties.

What this policy covers

This policy applies to employees, workers and contractors.

The Company constantly strives to safeguard and act in the interest of the public and its staff. It is important to the Company that any fraud, misconduct or wrongdoing, by employees or other agents, is reported and properly addressed.

This policy applies to all employees and all other agents of the Company, who are encouraged to raise concerns in a responsible manner. The Company prefers that a concern is raised and dealt with properly, rather than kept quiet.

Your responsibilities

You are encouraged to bring to the attention of the Company any practice or action of the Company, its employees or other agents that you reasonably believe is against the public interest, in that the practice or action is:

• a criminal offence
  
• a failure to comply with any legal obligation
  
• a miscarriage of justice
  
  
• a danger to the health and safety of any individual
  
• an attempt to conceal information on any of the above
  
  

Any individual raising legitimate concerns will not be subject to any detriment, either during or after employment. The Company will also endeavour to ensure that the individual is protected from any intimidation or harassment by any other parties.

This policy should not be used for complaints relating to your own personal circumstances, such as the way you have been treated at work, which should be raised under the Company's Grievance Procedure.

Procedure

In the first instance, you should raise any concerns you have with your manager. If you believe your manager to be involved, or if, for any reason, you do not wish to approach your manager, then you should raise it with a more senior person in the Company.

Any matter raised under this policy will be investigated promptly and confidentially. The outcome of the investigation, as well as any necessary remedial action to be taken, will be confirmed to you. If no action is to be taken, the reason for this will be explained to you.

Allegations regarding potential breaches of this policy will be treated in confidence and investigated thoroughly. If you raise any concerns under this policy, the Company is committed to ensuring that you are protected from victimisation, harassment or less favourable treatment. Any such incidents will be dealt with under the Company's Disciplinary Procedures.

Escalating your concern

If you are dissatisfied with this response, you should raise your concerns in writing directly with a more senior person in the Company.

If, after escalating your concerns, you believe that the appropriate remedial action has not been taken, you should then report the matter to the proper authority. These authorities include:

·HM Revenue & Customs

· the Financial Conduct Authority

· the Health and Safety Executive

· the Environment Agency or Scottish Environmental Protection Agency

· the Information Commissioner

This list is not intended to be exhaustive, and you must take care to ensure you contact the proper authority in relation to the particular concerns you have.

If you are unsure as to the appropriate authority, advice can be sought from Protect (formerly known as "Public Concern at Work") which is an independent Whistleblowing Charity. Their contact details are at the end of this policy.

If you raise a false allegation and you are found to be culpable, or in any way involved in the wrongdoing, or if you raise a concern maliciously or in a manner not prescribed in this policy, then you may be subject to disciplinary action up to and including dismissal without notice for gross misconduct.

You should not disclose to a non-relevant third party any details of any concern raised in accordance with this policy, and you must not, in any circumstances, publicise your concerns in any way.

Independent advice

Independent advice and support can be obtained from Protect (formerly known as "Public Concern at Work") (Independent Whistleblowing Charity):


Email address: whistle@protect advice.org.uk
Tel: 0203 117 2520
Website: www.protect-advice.org.uk

The overall goal of Electro South West is to provide products and services of the highest quality. To this end it is the policy of the company to ensure the quality management system is effective and conforms to the requirements of ISO 9001. In order to achieve this objective the company shall;

• Determine the needs and expectations of customers and other interested parties.
• Establish policies, objectives and a work environment necessary to motivate the organization to satisfy these requirements.
• Plan, resource and manage a system of interconnected processes necessary to implement the policy and attain the objectives.
• Measure and analyse the adequacy, efficiency and effectiveness of each process in fulfilling its purpose and objectives.
• Pursue the continual improvement of the system from an objective evaluation of its performance.

As part of the sanctions package against Russia following the invasion of Ukraine, importation of fasteners manufactured in Russia has been prohibited for some time. Electro South West Ltd. has always used suppliers that have complied with these requirements and none of our products have been sourced directly or indirectly from Russia.

The UK Government has recently announced enhanced sanctions which prohibits the importation of products made with Russian steel, even if they are made in a third country. These new sanctions take effect from 30th September 2023 and require importers to be able to prove that the steel in products being imported did not originate in Russia.

At Electro South West Ltd., we have been working with our suppliers for several months to ensure that we comply fully with these new sanctions.

Issue 01
October 2015

Scope – This documented procedure defines the methods to ensure that product which does not confirm to specification requirements is identified and controlled in order to prevent its unintended use or delivery. The procedure also defines the methods for the methods identifying, investigating, environmental complaints/ incidents and/or accidents/near misses and determining their causes.

Procedure for product non-conformity.

Electro South West ensures that product which does not conform to requirements is identified and controlled to prevent unintended use or delivery.

Electro South West deals with nonconforming product by one or more of the following ways; -

• by taking action to eliminate the detected nonconformity
• by authorizing its use, release or acceptance by concession by a relevant authority and, where applicable, by the customer
• by taking action to preclude its original intended use or application. -
• Or by taking action appropriate to the effects, or potential effects, of the non-conformity when non-conforming product is detected after delivery or use has started.

Suspect product may be identified by anyone in the Electro South West during any stage in the process, including:

• receiving inspection and testing
• in-process inspection and testing -
• customer returns

Product warranty and repair

• Goods returned will be received from customer using carboned triplicate book – one copy to customer, one copy attached to purchase order * and one copy retained in triplicate book

Information required :-

• A) Customers Name
• B) Date
• C) Customer contact details
• D) Fault if known
• E) If under warranty
• F) Repair required
• G) If estimate id required
• H) Product details, serial number etc!
• I) Customers Signature
• J) Staff member who collect/receives goods
• K) Staff members name arranging repair/warranty repair/estimate.

The staff member arranging repair/warranty produces a purchase order with the relevant supplier noting all the above details/ pin up returns copy *

Stock codes

• Supplier warranty – to be used for all goods still in warranty or guarantee
• Product repair – to be used for all other goods
• Tool resharpening – to be used for all re-sharpening etc.
• Electro plating – to be used for all electro plating

The same member of staff contacts the supplier to arrange collection of the goods noting any collection references on the purchase order (i.e. Contact, name, collection date, and lead time as well as collection number). Proof of purchase together with any information must be passed to the supplier

• A sales order must then be raised by the same member of staff again noting all the relevant details
• The supplier must be rung by the above staff if lead time expires
• All estimate for repairs must be relayed by the above members of staff to the customer – agreement for repair details and all costs to be added to sales order and purchase order at this point

Suspect product is segregated from other product and is placed within the quarantine area in order prevent its unintended use.

Nonconforming product is to be dispositional as follows:

• accepted by the customer under concession
• return to supplier
• scrap
  

The reason must be documented on the goods return and/or warranty return card.

All accidents, near misses, environmental complaints or incidents are to be investigated. This is order to establish the causes and to determine appropriate corrective and preventive actions to correct the issue and where possible prevent recurrence. Please refer to documented procedures for corrective and preventive actions. Records of all nonconformities and any actions taken, including concessions obtained, are maintained. These records are to be reviewed for effectiveness of the actions taken as part of the agenda for the monthly sales and purchasing meeting, periodic staff meetings and the annual management review meetings of the business management system. Please refer to the control of documents and records procedure.