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Employee Handbook A Guide to Working at Troy Asset Management Limited

1 November 2013

TROY ASSET MANAGEMENT LIMITED BROOKFIELD HOUSE, 44 DAVIES STREET, LONDON W1K 5JA TEL: 020 7290 7840 - FAX: 020 7491 2445


CONTENTS Page SECTION 1 – INTRODUCTION  Chairman Introduction

5

 How to use this Handbook

6

SECTION 2 - A CAREER WITH THE COMPANY  Corporate Governance & Company Structure

8

 Equality of Opportunity & Diversity

10

 Training & Development

11

 Continuing Professional Development

12

 Individual Performance

13

 Internal Openings & Promotions

14

 Membership of Professional Organisations

15

 Continuing Education & Professional Qualifications

16

SECTION 3 - BENEFITS & COVER  Pension Plans

19

 Life Assurance

20

 Personal Accident Cover

21

 Income Protection

22

 Critical Illness Insurance

23

 Private Medical Insurance

24

 Childcare Vouchers

25

 Cycle to Work

26

 Business Travel Insurance

27

SECTION 4 - HEALTH AND SAFETY AT WORK  Health & Safety Policy

29

 Non-smoking Policy

30

 Alcohol & Drugs

31

 First Aid & Accident Reporting

32

 Eye Tests

33

2


SECTION 5 – EMPLOYMENT ARRANGEMENTS  Personal Information

35

 Hours of Work

36

 Remuneration

37

 Holidays

38

 Termination of Employment

40

 Sickness Absence

42

 Other Absences

44

 Medical Examinations

47

 Family Arrangements

48

 Grievance Procedure

51

 Disciplinary Procedure

53

 Gross Misconduct

58

 Compliance

59

 Illegal or Unethical Business Practices

60

 Data Protection

61

 IT & Communications

62

 Dress Code

64

 Business Travel & Expenses

65

APPENDICES The following appendices contain supplemental information and are available separately. Appendix I

Useful Information & Contacts

Appendix II

Family Arrangements Supplemental Information

Appendix III

Fair Care Childcare Voucher Scheme Brochure

Appendix IV

Cyclescheme Cycle to Work Scheme Brochure

Appendix V

Helm Godfrey Employee Benefits Guide

Appendix VI

AXA PPP Healthcare Membership Handbook

3


SECTION 1

INTRODUCTION

4


INTRODUCTION

I am very pleased to welcome you to Troy Asset Management.

The Company was

founded to preserve and grow real value for our investors over the long term and it has flourished based on the core principles of simplicity, transparency and open dialogue. We run our business and our investors’ money with these principles very much at the forefront of our minds and this approach extends to our relationship with employees, shareholders and third-parties working for and on behalf of Troy. The handbook provides employees with a useful source of information relating to the Company and the arrangements and benefits of working here. It aims to provide clear and consistent advice and information in one place to ensure that questions and issues are dealt with quickly, fairly and consistently.

Jan Pethick Chairman

5


HOW TO USE THIS HANDBOOK This Employee Handbook (“the Handbook”) is an important source of information for all employees about working at Troy Asset Management Limited (“the Company”).

Section 5 of the Handbook provides information on employee arrangements, policies and procedures and should be read in conjunction with the Contract of Employment currently in place.

If there are any inconsistencies between the Contract of

Employment and the Handbook, the Contract of Employment will apply.

Supplemental information is provided separately as appendices to the Handbook.

Updates will periodically be necessary and the Company reserves the right to change any part of the Handbook from time to time. Reasonable notice will be given in respect of any changes. Changes will be communicated through the appropriate channels, and updated pages of the Handbook will be distributed to employees. Employees are required to update the Handbook when new pages are issued to ensure it remains current. An electronic copy of the latest version of the Handbook is available on the Company’s communal server.

Any questions regarding the Handbook, or any issue relating to employment with the Company should be raised directly with the Head of Operations, a director, or the Company’s appointed Human Resources Consultant (see Appendix I).

6


SECTION 2

A CAREER WITH THE COMPANY

7


CORPORATE GOVERNANCE & COMPANY STRUCTURE

The Company has established the following boards and committees to direct and govern its business.

The Board of Directors The Board of Directors (“the Board”) is the Company’s statutory board and is responsible for: 

determining the Company’s strategic objectives and policies;

monitoring progress towards achieving these;

appointing senior management;

approving annual budgets; and

accounting for the company’s activities to its shareholders.

The Board’s members are: Jan Pethick (Chairman), Simon de Zoete (Non-executive Director), James Findlay (Non-executive Director), Simon Robertson (Non-executive Director), Sebastian Lyon (Chief Executive), and Francis Brooke (Executive Director). William Davies is the Company Secretary.

Audit Committee

The purpose of the Audit Committee is to: 

appoint the Company’s external auditor;

oversee the working relationship and terms of engagement;

meet the appointed auditor at agreed points in the financial year;

review and approve the annual audit plan;

review the findings of the audit with the appointed auditor; and

review the effectiveness of the audit.

The Audit Committee meets at least twice a year, reports formally to the Board and its current members are: Simon de Zoete (Committee Chairman) and James Findlay. William Davies is the Committee Secretary. 8


Remuneration Committee

The purpose of the Remuneration Committee is to: 

set (and review the appropriateness of) the remuneration policy and framework for members of the Board and senior executives;

approve any performance-related pay schemes and share incentive schemes, employee benefits programmes and pension arrangements;

ensure that any contractual terms on appointment and termination and any payments made are fair and reasonable; and

review remuneration trends and appoint remuneration consultants as necessary to help fulfil its obligations.

The Remuneration Committee meets at least twice a year, reports formally to the Board and it current members are: Simon Robertson (Committee Chairman) and Jan Pethick. William Davies is the Committee Secretary.

Executive Committee

The purpose of the Executive Committee is to assist the Chief Executive in the performance of his duties, including: 

the implementation of strategy, policies and budgets set by the Board;

the development of operational plans and procedures;

the monitoring of operating and financial performance;

the assessment and control of risk;

the prioritisation and allocation of resources;

matters relating to personnel; and

monitoring competitive forces in each area of operation.

Members of the Executive Committee are appointed by the Chief Executive. Its current members are: Sebastian Lyon (Committee Chairman), Francis Brooke, William Davies (Committee Secretary), Fritz von Westenholz and Gabrielle Boyle. The Executive Committee meets monthly. Jan Pethick (Board Chairman) attends on a quarterly basis. 9


EQUALITY OF OPPORTUNITY & DIVERSITY

The Company is an equal opportunity employer. The aim of the Equal Opportunities policy is to ensure that no job applicant or employee receives any form of less favourable treatment on the grounds of age, disability, gender (or gender reassignment), race, national or ethnic origins, religion or belief, pregnancy or maternity, marital status (or civil partnership) or sexual orientation.

The Company will ensure that individuals are selected, promoted and treated on the basis of the individual's relevant skills, abilities and performance, and all employees will be encouraged to take advantage of the available facilities to progress their career within the Company.

The Company believes that a diverse workforce fuels innovative thinking and it actively promotes an open exchange of ideas and points of view in an environment of respect and dignity, where all employees feel valued and empowered to contribute to the decisions that affect them.

While overall responsibility for ensuring equal opportunities within the Company resides with the Chief Executive, the responsibility for day-to-day operation of the policy devolves down to all individuals professionally involved in recruitment, employee management and administration. Employees must also accept that they have a personal responsibility to help with the practical application of this policy. Any employee who believes that the Company has applied inequitable treatment should speak with their manager or a director, or raise the matter through the grievance procedure set out in this Handbook.

The Company is committed to monitoring the operation of this policy, and may review the procedures that will make it fully effective from time to time.

10


TRAINING & DEVELOPMENT

The Company recognises the important contribution that training, education and personal development make to its success. Employees are encouraged to take part in all aspects of Company training in order to maximally benefit performance and personal development. This training and development policy aims to:  provide induction training for new employees;  provide on-the-job training;  ensure that appropriate training is available to enable employees to reach and maintain satisfactory performance in their jobs;  provide information, instruction and training to ensure the health and safety of all employees; and  in accordance with the Company’s Equal Opportunity policy, ensure all training and development of employees does not unfairly or unlawfully discriminate.

Employees are also encouraged to identify specific training needs and proactively source and attend relevant courses and seminars to enhance their competence and performance.

11


CONTINUING PROFESSIONAL DEVELOPMENT

The Company has a Continuing Professional Development (“CPD”) programme to maintain levels of overall competence including both structured and unstructured activities designed to ensure the employee’s knowledge remains up to date.

This CPD programme aims to ensure that all employees review their competence on an on-going basis so that they remain competent in their job. Each employee is also responsible for maintaining and retaining records of their CPD activities, including updating the Company’s CPD log.

While employees who hold the regulated CF30 Customer Function are required to, all employees are encouraged to complete a minimum of 35 hours CPD by 31 December each year; including a minimum of 21 hours of structured CPD activities.

Examples of structured CPD activities include:  participating in seminars (web-based or in person);  lectures;  conferences;  workshops;  courses; and  completing e-learning modules and programmes.

Examples of unstructured CPD activities include:  continuing research relevant to the employee’s role;  participating in professional development coaching or mentoring sessions, which involve measurable objectives, targets and outcomes; and  reading industry and other relevant material.

12


INDIVIDUAL PERFORMANCE It is the Company’s policy to review the performance of its employees annually, and all new employees will be reviewed at the end of their probationary period of employment.

The Company has a performance review programme that provides a formal opportunity to discuss performance, review development and identify any training needs. The programme gives the chance to discuss and agree objectives for the year ahead. The employee may retain a copy of the completed forms for their files.

Outside the formal programme, all managers are encouraged to provide employees with ongoing guidance, feedback and assistance in respect of their employees’ performance and development. Similarly, all employees are encouraged to provide their own feedback and seek out the feedback of others.

Personal Job Profile For compliance purposes and to enhance individual performance, it is the Company’s policy to develop a personal job profile which clearly defines the main function, key responsibilities and key requirements of the role. A personal job profile will be developed with the employee and reviewed each year as part of the performance review programme to track career development.

13


INTERNAL OPENINGS & PROMOTIONS

The Company aims to fill openings internally, selecting on the basis of aptitude, skills, ability and performance. This provides opportunities for career progression. Recruiting from outside may be necessary when skills and experience are required that current employees do not possess or when the Company’s development outpaces the development of suitable employees.

14


MEMBERSHIP OF PROFESSIONAL ORGANISATIONS

At its absolute discretion, the Company may sponsor an individual employee’s membership in a professional association or institute when: 

it is directly related to activities and functions of the Company and the occupation of the employee;

it serves a useful purpose and is related directly to advancing the business interest of the Company;

it facilitates accomplishment of Company objectives;

it enables an employee to gain information of direct value to his or her job.

15


CONTINUING EDUCATION & PROFESSIONAL QUALIFICATIONS

The Company values education and continuous learning and may sponsor eligible employees for approved educational programmes that provide an opportunity to enhance present job knowledge and performance and to develop employees for prospective opportunities within the Company.

Eligible employees must have at least six months of continuous service and must be performing satisfactorily in their current job.

The Company will consider educational programmes provided by colleges and universities of higher education or further education, business or technical schools, recognised training organisations or distance learning bodies.

The Company may also consider other factors when approving an educational programme, for example, the capacity of the employee to complete the programme successfully whilst also managing his or her own work commitments, any potential impact on the employee’s team, and the employee’s own motivation to commence the programme. Educational programmes must not interfere with the Company’s normal work schedule. Travel, study and attendance at classes must be in the employee’s own time (save for approved time off set out below).

To apply for sponsorship for continuing education, the employee should speak to their manager and to the Head of Operations.

Sponsorship & Study Leave

The Company will cover the cost of the required tuition, registration fees and study materials. In addition to normal annual holiday, the employee may take up to two days leave per level (or equivalent) plus one day per exam.

16


The Company will not cover the cost of any resit examinations and any additional days required to resit will be taken from the employee’s annual holiday entitlement or as unpaid leave.

Supporting the employee through continuing education represents a considerable investment by the Company and it hopes to benefit from the employee’s knowledge and experience for some time. Therefore, in the event that the employee voluntarily resigns from the Company or voluntarily withdraws prior to completing the educational programme, he or she may be required to repay the direct expenses incurred under the programme in full. If the employee leaves the Company within two years of successfully completing the programme, he or she may be required to repay a portion of the direct expenses incurred.

17


SECTION 3

BENEFITS & COVER

18


PENSION PLANS

A retirement pension plan is provided for employees by the Company through a Group Personal Pension Plan (“the Pension Plan”) administered by Scottish Widows plc. Pension Advice is provided by the Company’s appointed benefits consultant.

Employees will be eligible to join the Pension Plan after they have successfully completed their probation period.

The Company will match employee contributions into the Pension Plan on a 2:1 basis up to a maximum Company contribution of 10%.

Pension contributions are

calculated as a percentage of gross monthly salary. The employee may contribute as little as they wish (although they must contribute a minimum of 2% to qualify for the Company contribution) or as much as they wish (noting prevailing restrictions on eligible tax relief).

The Company also operates a Pension Fund Accelerator salary sacrifice arrangement to provide the most tax efficient method of paying monthly pension contributions. The arrangement is renewed in April each year and is subject to a separate salary sacrifice agreement between the Company and the employee.

Further Details

For detailed information about the Pension Plan (including investment options and charges) and the Pension Fund Accelerator, employees should refer to the Employee Benefits Guide attached as Appendix V, which is prepared and maintained by the appointed benefits consultant.

The Company retains the right to amend or terminate the Pension Plan at any time and employees should note their benefits are always subject to the rules of the Pension Plan in force from time to time.

19


LIFE ASSURANCE

Life Assurance is provided for employees by the Company through a Life Assurance Scheme administered by Unum Limited.

Employees are automatically covered upon joining up to the age of 65 and ceases immediately at age 65 or when the employee’s service is terminated.

A lump sum equal to four times the current annual basic salary is payable should the employee die whilst in Company service.

Distribution of Benefits

The Life Assurance Scheme is administered by a discretionary trust and the scheme benefits are distributed at the discretion of the nominated Life Assurance Scheme Trustees. It is the employee’s responsibility to complete an “Expression of Wish” form to notify the Trustees of their intended beneficiary or beneficiaries.

Further Details

For detailed information about the Life Assurance Scheme (including benefits, restrictions, tax and Expressions of Wish) employees should refer to the Employee Benefits Guide attached as Appendix V, which is prepared and maintained by the appointed benefits consultant.

The Company retains the right to amend or terminate the Life Assurance Scheme at any time and employees should note their benefits are always subject to the rules of the Life Assurance Scheme in force from time to time.

20


PERSONAL ACCIDENT COVER

The Company operates a Personal Accident Insurance Policy.

Employees are

automatically covered upon joining and are covered 24 hours a day, worldwide.

Benefits

The policy compensates for accidental bodily injury, which solely, directly and independently of any other cause results in any of the following contingencies: 

death;

total and permanent loss of sight in one or both eyes;

total and permanent loss of hearing in one of both ears;

total and permanent loss of speech;

loss of one or more limbs;

any other total and permanent disablement.

The current Personal Accident Insurance Policy document details the current compensation sums, principal conditions and exclusions. This document is available for review by employees from the Head of Operations.

The Company retains the right to amend or terminate the Personal Accident Insurance Policy at any time and employees should note their benefits are always subject to the rules of the Personal Accident Insurance Policy in force from time to time.

21


INCOME PROTECTION

Income Protection cover is provided for employees by the Company through its Group Income Protection Scheme (“the Income Protection Scheme”) administered by Unum Limited.

Employees are automatically covered upon joining up to the age of 65 and ceases immediately at age 65 or when the employee’s service is terminated.

The Income Protection Scheme provides employees with 60% of their current annual basic salary following 26 weeks of continuous absence due to illness or incapacity (subject to satisfactory medical evidence and compliance requirement of the insurer).

Further Details

For detailed information about the Income Protection Scheme (including benefits, restrictions, taxation and claims) employees should refer to the Employee Benefits Guide attached as Appendix V, which is prepared and maintained by the appointed benefits consultant.

The Company retains the right to amend or terminate the Income Protection Scheme at any time and employees should note their benefits are always subject to the rules of the Income Protection Scheme in force from time to time.

22


CRITICAL ILLNESS INSURANCE

Critical Illness cover is provided for employees by the Company through its Group Critical Illness Insurance Scheme (“the Critical Illness Scheme”) administered by Unum Limited.

Employees are automatically covered upon joining up to the age of 65 (when cover will be subject to individual medical underwriting by the insurer, which may result in cover ceasing) and ceases immediately when the employee’s service is terminated.

A lump sum of up to two times the current annual basic salary (up to a maximum total sum of £500,000) is payable should the employee be diagnosed with a critical illness defined by the Critical Illness Scheme policy document.

Further Details

For detailed information about the Critical Illness Scheme (including rights, restrictions, definitions, tax, and how to claim) employees should refer to the Employee Benefits Guide attached as Appendix V, which is prepared and maintained by the appointed benefits consultant.

The Company retains the right to amend or terminate the Critical Illness Scheme at any time and employees should note their benefits are always subject to the rules of the Critical Illness Scheme in force from time to time.

23


PRIVATE MEDICAL INSURANCE

Private Medical Insurance cover is provided for employees by the Company through its Group Private Medical Insurance Scheme (“the Private Medical Scheme”) administered by AXA PPP Healthcare.

The Private Medical Scheme enables employees and their families to claim reimbursement for a range of specialist medical treatments in the UK up to certain limits.

Employees will be eligible to join the Private Medical Scheme after they have successfully completed their probation period. The benefit ceases immediately at age 65 or when the employee’s service is terminated.

Whilst new joiners to the scheme are required to complete an application form, they are not required to undergo a medical or complete a medical declaration. However, treatment of pre-existing medical conditions experienced during the previous five years are only covered by the Private Medical Scheme after the employee has been a member for two consecutive years, and, after being free from all symptoms and treatment relating to that condition for one year. Eligible treatment for all new conditions is covered from the date of joining.

Further Details

For detailed information about the Private Medical Scheme employees should refer to the Employee Benefits Guide attached as Appendix V, which is prepared and maintained by the appointed benefits consultant and also the AXA PPP Healthcare Membership Guide attached as Appendix VI.

24


CHILDCARE VOUCHERS

The Company operates a Childcare Voucher Scheme that facilitates the sacrifice of taxable income for tax and NI-exempt vouchers for working parents to pay for all or part of the cost of childcare.

Full details of the Scheme and Salary Sacrifice are set out in Appendix III.

25


CYCLE TO WORK

The Company operates a Cycle to Work Scheme that facilitates the sacrifice of taxable income for tax and NI-exempt vouchers for the loan of cycles and cyclists’ safety equipment to employees as a tax-free benefit, subject to a maximum loan of £1,000 plus VAT.

The employee will be to required repay the loan in a single pay period and the Company will reduce the employee’s salary before tax in that period by the full amount of the loan for the cycle and cyclists’ safety equipment.

Full details of the Scheme set out in Appendix IV.

26


BUSINESS TRAVEL INSURANCE

The Company operates a Business Travel Insurance Policy to insure employees whilst undertaking travel on Company business.

Employees are automatically covered upon joining and are covered whilst undertaking a journey on behalf of the Company outside the UK (or country of permanent residence) or in the UK if it involves an internal flight and overnight stay.

The current Business Travel Insurance Policy document details the current benefits, principal conditions and exclusions.

This document is available for review by

employees from the Head of Operations.

The Company retains the right to amend or terminate the Business Travel Insurance Policy at any time and employees should note their benefits are always subject to the rules of the Business Travel Insurance Policy in force from time to time.

27


SECTION 4

HEALTH AND SAFETY AT WORK

28


HEALTH & SAFETY POLICY

The Company aims always to conduct its activities in such a way as to minimise any possibility of danger to the health and safety of its employees and to other people using its premises. All employees have a duty, imposed by law, to take care of the health and safety of themselves, other employees and anybody else who may be on Company premises. It is a condition of employment that employees observe the Company’s Health and Safety Policy.

The Company is committed to: 

prevent accidents and cases of work-related ill-health and provide adequate control of health and safety risks arising from work activities;

provide adequate training to ensure employees are competent to do their work;

engage and consult with employees on day-to-day health and safety conditions and provide adequate information on occupational health;

implement emergency procedures in the case of fire of other significant incident;

maintain safe and healthy working conditions, provide and maintain equipment and ensure safe storage of any substances.

While responsibility for implementing and maintaining this policy lies with management, it is important that every employee understands that health and safety is an individual responsibility and that both the Company and its employees must work to achieve high standards of performance.

The Company expects every

employee to take their individual responsibility seriously.

Any employee who

notices anything that may be unsafe should take corrective action where it is safe to do so, or report it immediately to his or her manager.

Failure to observe safety regulations, or to use protective or other relevant equipment provided by the Company, will result in disciplinary proceedings.

Any suggestions to improve safety standards within the Company should be made to a director, who will take appropriate action.

29


NON-SMOKING POLICY

The Company aims to provide a healthy, safe, and clean working environment for all employees and other people using its premises and it expects its employees to observe their obligations in respect of the Smokefree (Premises and Enforcement) Regulations 2006. This policy sets out the standards which must be followed by all employees and this policy forms part of the Company's overall Health & Safety Policy.

It is forbidden for anyone (including all employees, contractors and visitors) to smoke on any Company premises. Smoking is also prohibited in any vehicles owned or leased by the Company and in private vehicles used for Company business if used to carry another employee, contractor or visitor. Any employee who is found to be acting in breach of this Policy will be subject to disciplinary proceedings.

The Company supports employees who wish to stop smoking. More information about available resources is posted on www.smokefree.nhs.uk.

30


ALCOHOL & DRUGS

The Company aims to maintain the highest professional standards. The misuse of alcohol and drugs affects an employee’s health and performance and can jeopardise safety in the workplace.

Alcohol at Work

To ensure a safe and productive work environment, the Company expects employees not to consume alcohol whilst at work or when carrying out their duties of employment. The only exception is for reasonable sociable alcohol consumption at events such as hospitality and employee social and networking events. Employees are expected to limit their consumption whilst off duty to ensure that they are not under the influence when commencing work or carrying out their duties of employment.

Drugs at Work

The Company prohibits the use of drugs on Company premises including any vehicles owned or leased by the Company or private vehicles used for Company business.

When drugs are prescribed by a medical professional, the employee must ask the prescribing professional if there are any side effects that may impair his or her ability to safely perform his or her duties of employment. If so, the employee must obtain a Fit Note indicating any work restrictions.

The misuse of alcohol and drugs may result in disciplinary proceedings up to and including dismissal.

If an employee is concerned about an alcohol or drug dependency, he or she is encouraged to seek professional help. The Company may, if it is concerned about the health and/or performance of an employee, request a medical examination. The Company may also support sound treatments to overcome alcohol and drug dependency. Information and help can be found at www.nhs.uk/livewell/addiction.

31


FIRST AID & ACCIDENT REPORTING

A First Aid box is kept on the Company premises. The Company has nominated a First Aider who should be the only employee who uses the First Aid equipment.

It is important that all accidents, however minor, are reported to the nominated First Aider and that individuals receive the necessary treatment. Each accident must be recorded in the Company’s accident register.

RIDDOR

Under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR), the Company has a duty to report serious incidents to the Health & Safety Executive.

To fulfil this requirement, the relevant manager must

immediately report any of the following incidents to the Chief Executive: 

a death arising from a work-related accident;

a major injury or condition arising from a work-related accidents;

work-related accidents causing more than three days' incapacity for work;

dangerous occurrences;

occupational diseases; and

any matter relating to the supply of gas.

32


EYE TESTS

The Company recognises its duty to comply with the Health & Safety (Display Screen Equipment) Regulations 1992 (as amended) and will cover the cost of a Display Screen Equipment eye and eyesight test every two years, up to a maximum of ÂŁ25 per test.

33


SECTION 5

EMPLOYMENT ARRANGEMENTS

34


PERSONAL INFORMATION

In order for the Company to be able to communicate effectively with employees, all employees must notify the Company immediately of any changes in personal information, such as: 

change of name, address or home telephone or mobile telephone number;

personal email address;

change of bank details;

date of marriage, civil partnerships, divorce, births or adoptions in the employee's immediate family;

change of intended life assurance beneficiary; and

change in the name, address or telephone number of next of kin, or person to be notified in case of emergency.

35


HOURS OF WORK

The normal hours of work are set out in the Contract of Employment. Employees may be required to work additional hours as may be reasonably necessary for the performance of their duties or as business needs dictate for which no overtime will be paid.

The efficiency of the Company's operations depends on the regular and punctual attendance of all employees, and all employees, therefore, are expected to make every effort to cooperate in this requirement. If an employee has the occasion to arrive late in the morning or needs to leave early in the evening for any reason, he or she should obtain the prior permission of his or her manager.

36


REMUNERATION The employee’s salary and basis of review is set out in the Contract of Employment. Any change in the employee's salary will be confirmed in writing. Salary is paid monthly in arrears on or around the 20th working day of each month by credit transfer to the employee's bank account.

Outstanding Sums of Money

In order to settle any liabilities quickly and without undue delay, the Company reserves the right to deduct any sums of money owed from any money that may be due to the employee from the Company. Should any amount owed to the employee by the Company be insufficient to cover any sums owed to the Company by the employee, the Company may, in addition, seek reimbursement directly from the employee for the excess.

In addition, the Company has an obligation in certain circumstances to make other deductions from an employee's pay, including payment for community charges, maintenance orders, student loans and other court orders.

37


HOLIDAYS

The Company's holiday year runs from 1 January to 31 December.

The Company recognises all statutory paid public holidays in the holiday year. These are currently: New Year’s Day Good Friday Easter Monday May Day Spring Bank Holiday Summer Bank Holiday (last Monday in August) Christmas Day Boxing Day

The Company will also recognise any special public holidays that may be declared during the year. If an employee is required to work on a public holiday, a day in lieu will be granted.

Annual Holiday Entitlement

The full-time annual holiday entitlement is as follows, in the: First, second, third and fourth holiday year:

25 days

Fifth holiday year:

26 days

Sixth holiday year:

27 days

Thereafter:

28 days

Partial Year Entitlement

If an employee does not join the Company at the beginning of a holiday year, the holiday entitlement for the partial year worked will be calculated on the basis that one-twelfth of annual entitlement will accrue for each full month worked. Fractions of a day will be rounded up to the nearest half-day.

38


If an employee leaves employment part-way through the holiday year, holiday entitlement will be calculated on the basis that one-twelfth of annual entitlement has accrued for each full month worked. Fractions of a day will be rounded up to the nearest half-day.

Part-time Working

When an employee has agreed to work hours less than the standard 37.5 hour week, both statutory paid public holidays and the employee’s annual holiday entitlement will be pro-rated to the number of hours worked. Company premises are closed for statutory public holidays, if the part-time employee has used up their pro-rated entitlement for statutory public holidays, he or she will be required to use their annual holiday entitlement or take unpaid leave on remaining statutory public holidays.

Booking Holidays

Holidays should be agreed as far in advance as possible with the employee's manager and must be taken at times convenient to the Company. Approved holidays should be diarised in Outlook and copied in to the employee’s manager and any other relevant individuals for information.

The smallest unit of holiday which may be taken is half a day. Employees are encouraged to take at least one two-week holiday each year. More than two weeks consecutive holiday may only be taken with the prior approval of a director. The Company reserves the right to refuse holiday requests if work demands require.

At the discretion of a director, up to three unused holidays may be carried forward from one holiday year to the next. These must be used by 31st January, or lost.

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TERMINATION OF EMPLOYMENT

On termination of employment, an employee is required to comply with the Procedure on Termination of Employment, set out below.

Notice Periods

After satisfactory completion of the Probationary Period, the period of notice that must be given by either party to terminate the employment contract is set out in an employee's Contract of Employment.

An employee who terminates employment is required to give contractual notice of termination of employment in writing to his or her manager.

When the Company terminates an employee's employment, it will give the employee contractual notice of termination of employment in writing (except where the termination of employment is due to gross misconduct).

Whilst working their notice period, employees are expected to remain focused, achieve agreed objectives and arrange an orderly hand-over of work.

Company Property On termination of employment (or any time during employment at the Company’s request), the employee must return all property (including but not limited to documents, computer hardware and software, mobile phone and smartphone devices, electronic equipment, credit or charge cards, keys, security passes) belonging to the Company on or before the date of leaving. Documents include but are not limited to hardcopy or electronic books, correspondence, files, statistics, papers, materials, reports, minutes, plans, records, surveys, diagrams, computer printouts, computer disks, USBs, DVDs, CDs, audio tapes, manuals, customer documentation or any other medium for storing information and all copies, drafts, reproductions, notes, extracts or summaries in whatever form.

40


Remuneration

The employee's final salary will be calculated and paid up to the date of leaving. It will be paid into his or her bank account in accordance with the normal payroll schedule. Payslips and P45 forms will be handed to the employee on or around the last day of work or forwarded to the home address, whichever is appropriate.

The Company will notify the Pension Administrators of the employee's date of leaving. The Pension Administrators will contact the employee directly to advise him or her of the pension options.

Outstanding Holiday Entitlement

The Company may require the employee to take all or part of any outstanding holiday during his or her notice period.

On termination of the employee's employment, payment will be made by the Company in respect of any holiday entitlement unused at the date of termination. For these purposes, holiday entitlement shall be deemed to accrue at the rate of onetwelfth of the annual entitlement (excluding days carried forward from a previous year) for each completed month worked. Fractions of a day will be rounded up to the nearest half-day.

If, on termination of employment, holiday entitlement in excess of the calculated amount has been taken, the Company reserves the right to deduct an amount equal to the excess holiday taken from any salary or other sums due to the employee on termination.

Payments or deductions in respect of holiday will be calculated on the basis that one day equals 1/260 of base salary (or pro-rated for part-time workers).

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SICKNESS ABSENCE

If an employee feels unwell while at work, he or she should speak to his or her manager. If the employee is considered to be unfit for work, arrangements will be made to send the employee home.

In order to carry out its business, the Company needs to have confidence in the level of attendance of its employees. Repeated or prolonged sickness absence causes disruption to business activities and places additional stress on colleagues. For these reasons, the Company will monitor all cases of sickness absence and take appropriate action, for example: 

recommend that further medical advice be sought;

request the employee to undergo a medical examination;

a reduction or cessation of any Company sick pay;

conduct a return-to-work interview; or

disciplinary proceedings.

Notification of Sickness Absence

All employees must follow the sickness administrative procedures detailed below in the event of absence from work due to sickness or injury. Failure to do so may result in Company sick pay being withheld.

Should an employee be unable to report for work as a result of sickness, injury or any other reason, the employee or someone acting on their behalf must telephone the employee's manager before 9.00 am on the first day of sickness explaining the reason for absence.

All employees must keep their manager informed of their progress and the likely date of return to work. For absence longer than a week, the employee should contact the Company at least once a week unless otherwise agreed.

Unauthorised absence from work may result in disciplinary proceedings and/or pro-

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rata deduction from salary. Continued unauthorised absence from work can result in termination of employment.

Return to Work after Sickness Absence

When an employee returns to work after absence due to sickness, the following procedure should be followed.

If an employee is absent from work for a period of a half day to five days inclusive as a result of sickness or injury, the Company may request the employee complete a self-certification form on return to work.

If the absence exceeds five working days, arrangements should be made for a Statement of Fitness for Work (“Fit Note�) signed by a registered medical practitioner or the authorised officer of a hospital to be sent promptly to the Company. Thereafter, Fit Notes must be sent at regular intervals unless other arrangements have been agreed upon with the employee's manager. A final Fit Note must be submitted on return to work.

The Company may request that the employee attend a return-to-work interview with his or her manager to discuss the circumstances of the absence and ensure the employee is fit for work. This is also an opportunity to brief him or her on work activities missed.

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OTHER ABSENCES

Medical, Dental and Optical Appointments

Routine medical, dental and optical appointments should ideally be arranged outside normal working hours.

If this is not possible the employee must obtain prior

permission from his or her manager for time off to attend appointments.

Compassionate Leave

In the case of the death or serious illness of an immediate family member (employee's spouse or partner's father, mother, brother, sister, or child), the Company will consider granting compassionate leave. The amount of leave granted is at the discretion of the Company and the following factors will be taken into account: 

the relationship between the employee and the family member;

the employee's involvement in the health care or funeral arrangements;

the distance to be travelled; and

the employee's general record.

As a guide and subject to the factors listed above, the Company may grant up to three days in respect of compassionate leave. Any employee who wishes to be considered for compassionate leave should raise the matter in the first instance with his or her manager.

Other Absences

It is the policy of the Company to provide employees with full or partial pay for certain absences. Prior written approval is needed for the following absences:

Military Service

If an employee with more than one year of service is required to attend a military service programme, the Company will pay the difference between the military pay

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and the basic salary during that period for up to two weeks in any year. The Company will grant half of the time as additional leave, and the employee must make up the other half from annual leave entitlement.

Jury Service

Time off with pay will be granted for jury service, provided the employee gives the manager a copy of the jury service notice before leave is required. The Company reserves the right to seek a postponement of jury service if absence would seriously disrupt the operation of business. Time off for jury service will not count towards annual leave entitlement but the employee must claim for loss of earnings and provide to the Company a copy of the certificate and the earnings statement provided by the Court detailing the amount paid to the employee. On production of these copies, the Company will top-up pay to the usual amount.

Time Off for Dependants

Employees are entitled to unpaid time off for dependants. This allows employees to take reasonable time off work to deal with certain unexpected or sudden emergencies, and to make any necessary longer term arrangements.

A dependant is a spouse, partner, child or parent or a person who lives with the employee (but is not a lodger or flatmate).

Employees can take leave when: 

a dependent falls ill, or is injured;

a dependent goes into labour;

he or she needs to make longer term care arrangements for a dependant who is sick or injured;

he or she has to deal with unexpected care arrangement cancellations;

he or she has to deal with an incident involving the employee’s child/ren.

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Religious Holidays

All religious holidays that are not national public holidays (England and Wales) will normally be taken as part of the employee's annual holiday entitlement.

Unauthorised Absence

If an employee does not report to work and has not pre-agreed any absence with their manager or followed the correct procedure, then the absence will be unauthorised unless there are acceptable mitigating circumstances. Unauthorised absence will be deducted from the employee’s holiday entitlement and continuous unauthorised absences may result in disciplinary proceedings.

Employee Safety and Security

For safety and security reasons, employees must ensure the Company is aware of their whereabouts during working hours. If an employee is delayed or is not able to be where they are expected to be, he or she must always ensure that their manager or a colleague is informed.

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MEDICAL EXAMINATIONS

Employees may be required to undergo a medical examination to provide the necessary information for the insurers of the Life Assurance benefits.

In other

circumstances, to safeguard both the Company's and the employee's interests, the Company may ask an employee to be examined by a doctor nominated by the Company. Such circumstances may include the following: 

on returning to work after absence because of sickness or injury, usually if that absence is for at least five working days;

if it appears to the Company that an employee may be suffering from a medical condition which adversely affects performance at work; and

where there are recurrent short-term absences.

Unreasonable refusal to co-operate in a medical examination may result in disciplinary proceedings.

The doctor will give the Company an opinion, which will be kept confidential, as to the employee’s fitness or otherwise for work. An employee will be notified at the appropriate time of his or her rights under the Access to Medical Reports Act 1988.

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FAMILY ARRANGEMENTS

The Company complies with the statutory provisions on Maternity Leave and Maternity Pay, Paternity Leave and Paternity Pay and Adoption Leave and Adoption Pay. These provisions are clearly set out on the Government’s information pages, updated from time to time. Detailed provisions are set out in Appendix II and will be updated from time to time, a summary of which is provided below.

Maternity Leave and Pay

If an employee is pregnant and intends to claim Maternity Leave or Maternity Pay, she should discuss the matter with her manager or the Head of Operations at the earliest possible opportunity. The prevailing statutory provisions will be discussed and confirmed together with maternity benefits and the obligations of both the employee and the Company.

Discretionary Maternity Pay The Company agrees to enhance Statutory Maternity Pay (“SMP”) for those employees with more than one year’s service at the 15th week prior to the Expected Week of Childbirth (“EWC”).

This will enhance the payment during Ordinary

Maternity Leave (“OML”) as follows:  if more than SMP, the first 12 weeks at 100% of weekly basic salary (at the rate of pay prevailing at the commencement of Maternity Leave);  if more than SMP, the following 6 weeks at 50% of weekly basic salary (at the rate of pay prevailing at the commencement of Maternity Leave);  for the remaining 21 weeks; flat rate SMP determined by the Government from time to time. These payments are paid at the absolute discretion of the Company. Any payments made are inclusive of SMP entitlements and subject to Income Tax and National Insurance in the normal way.

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Paternity Leave and Pay If an employee’s spouse is pregnant and he intends to claim Paternity Leave or Paternity Pay he should discuss the matter with his manager or the Head of Operations at the earliest possible opportunity. The prevailing statutory provisions will be discussed and confirmed together with paternity benefits and the obligations of both the employee and the Company.

Discretionary Paternity Leave and Pay

The Company agrees to enhance Statutory Paternity Pay (SPP) for those individuals with more than one year’s service at the 15th week prior to the EWC.

This will

enhance the payment during Ordinary Paternity Leave (OPL) as follows:  if more than SPP, the 2 weeks of OPL at 100% of weekly basic salary (at the rate of pay prevailing at the commencement of Paternity Leave). Employee’s eligible for Discretionary Paternity Pay cannot carry over Paternity Leave outside the Paternity Leave Period. He must take the leave as two consecutive weeks or two blocks of one week. It is not possible to take odd days.

Adoption Leave and Pay

If an employee is intending to adopt and claim Adoption Leave or Adoption Pay, he or she should discuss the matter with their manager or the Head of Operations at the earliest possible opportunity. The prevailing statutory provisions will be discussed and confirmed together with adoption benefits and the obligations of both the employee and the Company.

Discretionary Adoption Pay

The Company agrees to enhance Adoption Pay equivalent to the enhanced Maternity Pay or enhanced Paternity Pay set out above, whichever is relevant.

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Parental Leave

Parental Leave is up to 18 weeks unpaid leave to care for a child and is available to any employee who: 

has one year’s continuous service with the Company;

is named on the child’s birth or adoption certificate;

has or expects to have parental responsibility;

has a child who is under 5 (or 18 in special circumstances).

The limit on how much parental leave can be taken in one year is four weeks which must be taken in blocks of one week.

Flexible Working

Eligible employees are entitled to request a flexible working arrangement to care for a child, which, if granted, will be a permanent change to their terms and condition of employment.

Whilst the Company will make every effort to accommodate such a

request, it reserves the right to refuse if certain business grounds apply.

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GRIEVANCE PROCEDURE

It is expected that most problems will be resolved informally between the employee and manager. However, in the event that a matter is not settled, the Company has a standard grievance procedure for all employees, set out in full below. Whilst this does not form part of the contract of employment with the Company, it is important that all employees read and understand the procedure that should be followed in the event of a grievance.

A grievance is a work-related concern, problem or complaint.

Principles

The aim of this grievance procedure is to ensure that problems that cannot be resolved informally are resolved fairly and promptly, in an atmosphere of mutual respect, and following the principles set out below:  the Company will appoint an appropriate manager or director to manage the grievance procedure;  any grievance will be settled as near the point of origin as possible;  the employee may be accompanied by a fellow employee at any meetings that may take place under the grievance procedure;  the employee may appeal any decision reached under the grievance procedure;  any grievance will be treated as strictly confidential, unless otherwise agreed.

Procedure

In the first instance, an employee should raise the grievance formally in writing to his or her manager without any unreasonable delay. The grievance should clearly set out the nature of the problem.

The Company will arrange meetings as necessary to hear the details of the grievance and conduct any investigations. The employee may invite a fellow employee to attend such meetings.

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Following the meeting/s the Company will respond to the employee’s grievance in writing and set out the decision made and, where appropriate, what actions will be taken.

Appeal

If, once the grievance procedure has been followed, an employee feels that their grievance has not been satisfactorily resolved they may appeal.

An appeal should be made in writing to the Chief Executive without any unreasonable delay. The appeal will be heard as soon as reasonably practicable following receipt of the notice of appeal. After the appeal meeting, the Chief Executive will make a decision to uphold the previous decision, reverse the decision, or to amend any of the actions decided. This decision will be final. Where the employee’s manager and the Chief Executive is the same person, the employee may appeal in writing to the Chairman.

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DISCIPLINARY PROCEDURE

The Company maintains a disciplinary procedure that facilitates the discussion, review, and resolution of problems related to the employee's attendance, job performance or conduct.

Cases of minor misconduct or unsatisfactory performance should be resolved informally between the manager and the employee. In situations where matters are more serious or where an informal approach does not bring about the improvement required the Company has a standard disciplinary procedure, set out in full below. Whilst this does not form part of the Contract of Employment with the Company, it is important that all employees familiarise themselves with this procedure (including Gross Misconduct) and that careful note is taken that certain offences can lead to immediate dismissal without pay in lieu of notice.

Principles

The aim of this disciplinary procedure is to ensure that problems that cannot be resolved informally are resolved fairly and promptly, in an atmosphere of mutual respect, and following the principles set out below:  the Company will appoint an appropriate manager or director to manage the disciplinary procedure;  problems will be addressed as consistently as possible;  problems will be properly investigated before any decisions are made;  the employee will be advised on the nature of the problem and will be given an opportunity to respond before any action is taken;  the employee may be accompanied by a fellow employee at any meetings that may take place under the disciplinary procedure;  the employee may appeal any decision taken under the disciplinary procedure;  the problem will be treated as strictly confidential, unless otherwise agreed;  no employee (not including those serving a probationary period) will normally be dismissed for a first breach of discipline, except in the case of gross misconduct (examples of which are provided under the heading Gross Misconduct in this 53


Handbook);  any action imposed under the disciplinary procedure will not be disproportionate to the nature of the problem.

Procedure

In all cases other than instant dismissal, the following procedure will apply: i)

the Company will inform the employee of the problem in writing;

ii) a meeting will be arranged discuss and investigate the facts; iii) the Company will decide the course of action and inform the employee.

If action is taken under this disciplinary procedure, the Company will write to the employee to set out the nature of the problem and the grounds for contemplating disciplinary action. The employee will be invited to attend a meeting to discuss the matter. The employee will receive at least 3 working days’ notice of any meeting. The employee may invite a fellow employee to accompany them at the meeting.

If at the meeting either party intends to refer and rely upon evidence relevant to the problem, a copy of such evidence should be provided in advance of the meeting (subject to any confidential information being deleted, where necessary).

At the meeting, the Company representative will summarise the nature of the problem and the employee will have the opportunity to explain his or her case and refer to any evidence upon which he or she intends to rely. It may be necessary to undertake further investigation, in which case the meeting may be adjourned and reconvened within a reasonable period of time.

After the meeting, a decision will be made and the employee will be informed of the decision and any disciplinary action to be taken.

Stages of Disciplinary Action

Once the disciplinary meetings and investigations have been fully completed, the Company will decide the appropriate disciplinary action, as follows: 54


 No action;  Formal verbal warning;  Formal written warning;  Final written warning;  Dismissal.

Formal Verbal Warning

For minor acts of misconduct, or if the employee fails to meet the required standard of work performance, a formal verbal warning may be given. The warning will be recorded on the personal file and removed after 6 months if no further misconduct occurs or the standard of work performance improves.

First Written Warning

For more serious acts of misconduct, or further acts of misconduct, or a continuing failure to meet the required standards of work performance, a first written warning may be given. A formal written warning will be recorded on the personal file and removed after 12 months if no further misconduct occurs or the standard of work performance improves.

Final Written Warning

In the event of serious acts of misconduct, or further acts of misconduct, or failure (or continued failure) to meet the required standards of work performance, a final written warning may be given. A final written warning will specify that the consequence of further acts of misconduct or failure to meet the required standards of work performance will normally be dismissal.

This warning will be recorded on the

personal file and will be removed after 12 months if no further misconduct occurs or the standard of work performance improves.

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Dismissal

In the event of any further misconduct, or continued failure to meet the required standards of work performance, dismissal may result. If the employee is dismissed, the Company reserves the right to require the employee to work their notice period or to pay in lieu of notice.

Confirmation of Disciplinary Action

The Company will confirm in writing its decision and any disciplinary action to be taken, in which case, it will also include details of: 

the nature of the problem;

the improvement required;

the time scale for the achievement of the required improvement (if appropriate);

the range of consequences which may follow if there is repetition of the misconduct or continued failure to meet the required standard; and

the process the employee should follow to appeal.

Additional Information

The disciplinary procedure does not apply to the termination of employment during a probation period, or at the end of the probation period, whether or not it was extended beyond its originally specified duration.

The Company may enter the disciplinary procedure at any of the stages set out above as it deems appropriate according to the gravity of the misconduct or the extent of the poor performance under consideration.

If an employee has been warned for one type of offence and commits another offence of a different nature within 12 months of that warning, they may be liable to the next stage of disciplinary action.

The Company may suspend any employee on full pay while investigations (which

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may lead to disciplinary action) are carried out.

Factors which may be relevant in deciding disciplinary action, if any, include the extent to which standards of conduct have been breached, any precedents, the employee’s general record, position, length of service and any special circumstances which might make it appropriate to adjust the severity of the sanction.

Appeal

The employee may, within five working days of a decision being made under any stage of the disciplinary procedure, appeal against that decision.

An appeal should be made in writing to the Chief Executive. The appeal will be heard as soon as reasonably practicable following receipt of the notice of appeal. After the appeal meeting, the Chief Executive will make a decision to uphold the previous decision, reverse the decision, or to reduce any sanction. This decision will be final. Where the employee’s manager and the Chief Executive is the same person, the employee may appeal to the Chairman.

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GROSS MISCONDUCT

Some disciplinary offences are so serious that they warrant immediate dismissal (with neither notice nor pay in lieu of notice) under the disciplinary procedure, without first going through the earlier stages.

These offences, referred to as offences of gross misconduct, include the following:  dishonesty, including theft or fraud;  unauthorised use or disclosure of confidential information, including any breach of client confidentiality, subject to the Public Interest (Disclosure) Act 1998;  serious breach of the Company’s data protection rules;  falsification of the Company’s records including expense claims;  serious insubordination;  violent, abusive or intimidating conduct, including bullying or harassment, and including incitement of such conduct;  serious misuse of the Company’s IT & Communications equipment and systems, including accessing or distributing material which is, or may be thought to be, defamatory, abusive, offensive, sexual in nature, or unlawfully discriminatory to the recipient or to any other individual;  unlawful discriminatory treatment of another person;  deliberate damage to the Company’s property;  any conduct likely to bring the Company into disrepute;  serious incapability whilst at work brought on by alcohol or illegal drugs;  serious negligence which causes or might cause unacceptable loss, damage or injury;  serious infringement of health and safety rules.

This illustrative list of offences of gross misconduct is not to be taken as exhaustive.

Where, after the disciplinary meeting and investigation, an employee is found guilty of gross misconduct, the employee will be provided with a letter setting out the Company’s findings, the date that employment will be terminated and the process the employee should follow should he or she wish to appeal the decision made. 58


COMPLIANCE

The Company has a comprehensive Compliance Manual which outlines the Company’s material regulatory obligations under the UK regulatory system and includes the Company’s schedule of policies and procedures in respect of the Financial Conduct Authority’s (FCA) Rules. In particular, the Compliance Manual sets out the Company’s policies and procedures regarding:  Personal Account Dealing  Best Execution  Order Execution  Aggregation and Allocation of Orders  Market Conduct  Market Abuse Risk Assessment  Conflicts of Interest  Reporting Suspicions of Money Laundering  Anti-Money Laundering (AML) and Counter Terrorist Financing (CFT) Regulations  Gifts, Benefits, Inducements and Anti-Bribery  Bribery Risk Assessment  Guidance on Whistleblowing  Data Security  Treating Customers Fairly (TCF) Framework of Objectives and Measures  Discretionary Investment Management (Retail Clients) Statement  Dealing Error

Matters of non-compliance will be treated very seriously. Breaches of any of the Rules may have serious implications for the Company and its employees, in particular, Approved Persons, who fail to meet their obligations.

All employees are required to sign an acknowledgement and undertaking which confirms their receipt and understanding of the Compliance Manual and related policies and procedures.

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ILLEGAL OR UNETHICAL BUSINESS PRACTICES

No employee is authorised to do business for or on behalf of the Company in such a manner as to knowingly violate the laws. In addition, no employee will act on or enter into an agreement which would or might have the appearance of an illegal or unethical act.

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DATA PROTECTION The Company complies with the Data Protection Act (“DPA”), in respect of data held. The DPA regulates the use of automatically processed information and paper records in a relevant filing system relating to individuals. The provisions of the DPA apply to anyone who controls the use of or has access to personal data relating to another individual. All employees are required to maintain the security of all personal data to which the employee may have access and only use or disclose such information as permitted by the Company.

The DPA regulates the use of personal data. "Data" is information that is:  recorded in a form in which it can be processed by equipment operating automatically in response to instructions given for that purpose; or  recorded with the intention that it should be processed by means of such equipment; or  recorded as part (or with the intention that it should form part) of a relevant filing system (i.e. any set of information relating to individuals to the extent that, although not processed as above, is structured either by reference to individuals or by reference to criteria relating to individuals, in such a way that specific information relating to a particular individual is readily accessible); or  part of an accessible record which includes a health record, educational record, local authority housing record or local authority social services record.

"Personal data" is data consisting of information which relates to a living individual who can be identified from that information (or from that and other information held by the data user) including any expressions of opinion about the individual but not any indication of the intentions of the data user in respect of the individual.

The Company complies with all aspects of the DPA and its principles, and rights of access for personal data are governed by its requirements. All employees are required to adhere to the Company’s guidelines and procedures in respect of Data Protection.

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IT & COMMUNICATIONS

The Company procures appropriate equipment and systems to enable employees to carry out the requirements of their job efficiently. Eligibility for equipment and systems will be determined by business need and the allocation of such may be revised or withdrawn at any time. Equipment allocated remains the property of the Company and must be returned to the Company on termination of employment.

Employees are expected to take care of equipment and systems allocated to them and not to install unauthorised applications or download unauthorised material.

Personal Use

The Company accepts reasonable personal usage of its equipment and systems provided that it does not interfere with the employee’s job and work performance. Employees are expected not to misuse the Company’s equipment and systems. In particular, it will regard as an offence of gross misconduct the accessing or distributing of distributing material which may be defamatory, abusive, offensive, sexual in nature, or unlawfully discriminatory in any way.

Social Media

The employee must always be mindful of the reputation of the Company and the confidentiality of its clients when accessing and using social media, including the use of both personal and work-related social networking sites.

Security Employees are expected to adhere to the Company’s policies and procedures on Data Security. They are also expected ensure the security of Company equipment and should take reasonable precautions to prevent laptops, mobile devices and data storage devices from loss, theft and vandalism.

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Electronic and telephonic transmissions are not secure and the employee should use discretion in relaying confidential information and should always be mindful of protecting the Company’s reputation and client confidentiality when utilising Company equipment and systems or employee-owned equipment for electronic and telephonic communications.

Smartphones

A standard smartphone or similar device and telephone number will be procured and issued to the employee by the Company at its absolute discretion. The employee may choose instead to use their own personal smartphone to access and manage electronic communications.

If electing to use an employee-owned device, the employee

acknowledges and accepts that the Company’s standards and expectations for conduct in respect of electronic communications will apply as if the employee had obtained a Company-owned device.

The Company will reimburse reasonable charges for work-related calls and connectivity through its usual Business Travel & Expenses procedure.

Whilst

travelling abroad, the Company will cover the cost of data-roaming and wireless connectivity for work-related electronic communications only.

Monitoring

The Company may, for lawful business purposes, monitor, check, record and review communications carried out using the Company’s communications equipment and systems, including but not limited to telephone calls, email and internet usage. This includes work-related electronic communications using employee-owned equipment.

The employee acknowledges and gives consent to the Company monitoring its communication and electronic equipment and systems, including, but not limited to, telephone calls, internet use, computer files, records and emails for compliance, security or risk analysis checks the Company considers reasonably necessary.

All Company fixed phones are recorded. 63


DRESS CODE

Whilst at work, employees are required to wear formal business attire. For gentlemen business suits, business shirts and ties are appropriate, and, for ladies, similarly, business suits or suitable separates or dresses.

Should any employee have difficulties interpreting or maintaining these standards they should discuss the matter with their manager. In extreme cases when an employee's appearance, in the Company’s view, contravenes the above guidelines, the employee may be required to return home to change into more suitable attire.

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BUSINESS TRAVEL & EXPENSES

The Company will reimburse all essential and reasonable expenses incurred relating to the requirements of work. It is the Company's intention that employees should neither lose nor gain financially.

Employees are expected to exercise good judgement and planning when making travel arrangements and should travel using the most economical method taking into account the circumstances of travel. Whenever possible, public transport should be used if it is cheaper than the use of an employee’s personal vehicle and is reasonably convenient. When travelling by rail, standard class rail travel should be used and when traveling by air, economy class, unless otherwise authorised by a director.

If using the employee's personal vehicle, business mileage can be claimed at a rate of 45p per mile, which may be amended from time to time. The employee must check that their vehicle insurance policy permits the use of the vehicle for business purposes.

Where an employee is required to travel on Company business and stay overnight, reasonable costs for meals and accommodation will be reimbursed.

Employees should recover their expenses as regularly as possible. He or she should provide original VAT receipts, together with supporting information, to the Office Manager who will process the reimbursement, arrange for it to be authorised and credited into the employee’s bank account.

The employee is responsible for the accuracy and validity of the expenses submitted. Submission of a fraudulent expense claim or the misappropriation of Company funds may lead to disciplinary proceedings up to and including dismissal.

Business Entertainment

HMRC requires business meals and entertainment expenses be wholly, necessarily

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and exclusively related to carrying on a trade or business. This means that there is a general expectation of generating future income or some other future business benefit.

Full details of business meals and entertaining expenses must be supplied together with the names of all guests when submitting VAT receipts for reimbursement. Failure to provide such supporting documentation may result in HMRC considering the expense as a personal benefit and apply personal income tax.

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APPENDICES

The following appendices are available separately: Appendix I

Useful Information & Contacts

Appendix II

Family Arrangements Supplemental Information

Appendix III Fair Care Childcare Voucher Scheme Brochure Appendix IV Cyclescheme Cycle to Work Scheme Brochure Appendix V

Helm Godfrey Employee Benefits Guide

Appendix VI AXA PPP Healthcare Membership Handbook

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Troy Asset Management - Employee Handbook