Shorefield Holidays Limited Policies Handbook

Policy Handbook

Anti-Corruption & Bribery Policy

The Directors of Shorefield Holidays Limited value its reputation for ethical behaviour and reliability. Shorefield Holidays Limited recognises that any involvement in corruption and bribery will also reflect adversely on the image and reputation of the Company. The aim, therefore, is to limit exposure to corruption and bribery.

The Policy

Shorefield Holidays Limited prohibits the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement to or from any person or company, wherever they are situated and whether they are a public official or body or private person or company by any individual employee, agent or other person or body acting on behalf Shorefield Holidays Limited’s behalf in order to gain any commercial, contractual or regulatory advantage for the Company in a way which is unethical or in order to gain any personal advantage, for the individual or anyone connected with the individual.

The Company has a strict anti-bribery policy in line with the Bribery Act (2010). A bribe is defined as: giving someone a financial or other advantage to encourage that person to perform their functions or activities improperly or to reward that person for having already done so.

If you bribe (or attempt to bribe) another person, intending either to obtain or retain business for the Company, or to obtain or retain an advantage in the conduct of the Company’s business this will be considered gross misconduct.

Similarly accepting or allowing another person to accept a bribe will be considered gross misconduct. In these circumstances you will be subject to formal investigation under the Company’s disciplinary procedures, and disciplinary action up to and including dismissal may be applied.

Inevitably, decisions as to what is acceptable may not always be easy. If anyone is in doubt as to whether a potential act constitutes bribery, the matter should be referred to the HR Manager before proceeding with any further action. If necessary, guidance should also be sought from the Financial Director.

Employee Responsibility

The prevention, detection and reporting of bribery is the responsibility of all employees throughout the Company.

Suitable channels of communication by which employees or others can report confidentially any suspicion of bribery will be maintained using the Whistleblowing Policy.

Your working relationships may bring you into contact with outside organisations where it is normal business practice or social convention to offer hospitality, and sometimes gifts. Offers of this kind to you or your family can place you in a difficult position.

Therefore, no employee or any member of his or her immediate family should accept from a supplier, customer or other person doing business with Shorefield Holidays Limited, payments of money under any circumstances, or special considerations, such as discounts or gifts of materials, equipment, services, facilities or anything else of value unless:

▪ they are in each instance of a very minor nature usually associated with accepted business practice

▪ they do not improperly interfere with your independence of judgement or action in the performance of your employment

In every circumstance where a gift is offered, the advice of the Financial Director or HR Manager must be sought. Where the employee has permission to accept hospitality then this must be entered in the hospitality logs

Contravention of this Policy

Failure to comply with any of the requirements of this policy is a disciplinary offence and may result in disciplinary action being taken under the Company’s disciplinary procedure. Depending on the seriousness of the offence, it may amount to gross misconduct and could result in the employee’s summary dismissal.

Bullying & Harassment Policy

Shorefield Holidays Limited is opposed to bullying or harassment in any form and will not tolerate either of these during the course of employment. This also includes at office/team social events (whether organised by Shorefield Holidays Limited or not) or at informal events involving employees, customers or other work-related contacts.

The Company aims to provide a working environment free from bullying and harassment.

Harassment

Harassment is a particular form of discrimination that may involve inappropriate actions, behaviour, comments or physical contact that causes offence and affects an individual’s dignity at work. Harassment may make the recipient feel threatened, humiliated or patronised and creates an intimidating working environment.

Harassment is defined by the impact on the recipient and not the intention of the harasser and may involve a single incident or persistent behaviour that extends over a period of time.

Incidents of harassment are generally very sensitive and are often complex in nature. The aim of this policy is to stop the undesirable conduct and prevent a recurrence.

Harassment can take many forms including sexual harassment, racial harassment, bullying, intimidation, “mobbing”, and victimisation.

Sexual harassment may take the form of requests for sexual favours, unwelcome or offensive contact of a sexual nature, leering, or lewd pin-ups in the workplace. This can affect both male and females, and come from any gender that may be other colleagues or more senior employees.

Racial harassment can be treatment afforded to an employee because of that person’s racial origins, insults and racist comments based on colour, race, nationality or ethnic origin. This may take the form of comments or actions, name calling, displaying racially offensive material or jokes of a racial nature. Harassment can also occur if employees use the internet or e-mail to store or distribute abusive or offensive material.

Bullying

Bullying can be described as unwanted behaviour from a person or group that is either:

▪ offensive, intimidating, malicious or insulting

▪ an abuse or misuse of power that undermines, humiliates, or causes physical or emotional harm to someone. The bullying might:

▪ be a regular pattern of behaviour or a one-off incident

▪ happen face-to-face, on social media, in emails or calls

▪ happen at work or in other work-related situations

▪ not always be obvious or noticed by others Examples of bullying at work could include:

▪ someone has spread a malicious rumour about you

▪ your boss keeps giving you a heavier workload than everyone else

▪ someone keeps putting you down in meetings

▪ someone holding back information or deliberately "losing" information

▪ being excluded from team social events

▪ someone has put humiliating, offensive or threatening comments or photos on social media

▪ someone at the same or more junior level as you keeps undermining your authority

Bullying is not:

▪ Being held accountable for your performance or behaviour

▪ Constructive feedback

▪ Conflict or difference of opinions

Bullying and harassment are often confused. By law (Equality Act 2010), bullying behaviour can be harassment if it relates to any of the ‘protected’ characteristics; age, disability, gender reassignment, race, religion or belief, sex and sexual orientation

Types of bullying can range from extreme forms of violence and intimidation, threatening behaviour, swearing and shouting, humiliating the victim in front of others to the less obvious, such as “sending someone to Coventry” (a term widely used for refusing to speak to and ignoring an individual) and managing by intimidation or threat.

The results of bullying and/or harassment can be

▪ increased absenteeism

▪ stress and anxiety

▪ poor performance

▪ poor working environment

▪ low morale

▪ high labour turnover

This can affect the whole Company and productivity which in turn has major consequences.

Bullying and harassment are detrimental to mental health not only for those directly affected but for everyone around the individual including friends, family, colleagues etc.

If you have witnessed bullying, harassment or discrimination its best not to stay silent. If you can, speak to the person to who the negative behaviour is directed towards and ask them what support they need.

It is important that if you feel that you or someone you work with is the victim of bullying or harassment then you follow the procedure and report it to the right person for the correct action to be taken.

Social media

If you put potentially offensive or inappropriate comments or images about or directed at colleagues or customers on social media sites/communication platforms, we take this very seriously and will investigate it in line with this policy. There’s more information in our Social Media Policy

The Procedure

In both instances, complaints should be treated with sensitivity and confidentiality. If the matter has to be given to another manager to be investigated, the employee must be made aware. Whether informal or formal, all complaints will be handled, as far as possible, in a confidential and timely manner.

Informal Procedure

The informal procedure may be appropriate for resolving complaints where you feel that the bullying and/or harassment is of a low level of severity and is causing you minor offence. If you feel able to you should in the first instance:

▪ Inform the individual responsible that their behaviour is unwelcome or unacceptable and ask them to stop. They may not be aware that their behaviour has caused offence

Or

▪ Discuss the situation confidentially with your Head of Department, or a member of the HR Department if more appropriate, and ask that an informal approach be made to the person(s) causing the offence by using mediation if agreed or an informal conversation to enlighten them of the offensive behaviour and ask them to stop. Again they may not be aware that the behaviour has caused offence and so therefore the approach/outcome should be modified to reflect this

A record needs to be made of all incidents, detailing the complaint including all relevant evidence you/they may have, the actions taken to stop the harassment and also details of any requests for assistance that you/they have made. All records should be forwarded to the HR Team to be held confidentially.

If the behaviour continues, you should contact your Head of Department or HR, to try and resolve the complaint formally in line with the Grievance Procedure. Formal Procedure

The formal procedure may also be more appropriate in instances of serious complaint or where an attempt at informal resolution has been unsuccessful.

▪ If you believe that you have been subjected to bullying/harassment, you should put your complaint in writing to your Head of Department in the first instance or if this is not appropriate the a member of the HR Team.

▪ Your complaint should include all relevant details, including any documentary evidence, names of witnesses and any action which has been taken to date. It is in the best interests of all the parties that a complaint of bullying/harassment is raised as early as possible, when details are still clear in your mind.

▪ Within 5 working days of receipt of the written complaint or as soon as reasonably practicable due to operational circumstances, your Head of Department or the HR Representative will instigate an investigation. The investigation will be conducted by someone senior or supervisory who has not had any previous involvement in the matter and this may include interviewing you, the alleged bully/harasser and any witnesses detailed in the complaint.

▪ During the investigation, it may be appropriate to keep you and the alleged bully/harasser apart and a decision may be taken to suspend on full pay (in serious cases), or temporarily transfer, one or both parties, pending the resolution of the complaint.

▪ If, following investigation, the complaint is found to be substantiated, immediate and appropriate action will be taken to stop the harassment and prevent any recurrence. A decision may be made to initiate the disciplinary procedure.

▪ You will be informed of the outcome of the investigation.

Where disciplinary action is considered appropriate, a disciplinary interview will be arranged and the matter will be dealt with in accordance with the Company’s Disciplinary Procedure.

Shorefield Holiday Limited take all complaints seriously, and no employee who makes a complaint in good faith, or participates in an investigation of a complaint, will be victimised for doing so.

Complaints that are not made in good faith and involve deliberate misuse of the above procedure will result in disciplinary action being taken against the complainant.

Capability Policy & Procedure

This policy is outlines Shorefield Holidays Limited’s procedures for addressing and supporting employees who are not meeting performance expectations due to a lack of skills, knowledge, or ability. This policy defines when underperformance is deemed to be due to a lack of capability, distinguishing it from issues like poor attendance or deliberate poor performance

What is a capability issue?

Capability refers to an employee's inability to perform their duties to the required standard, due to a lack of skills, aptitude, or other factors beyond their control. It's distinct from conduct issues, which relate to inappropriate behaviour or violations of company rules. Capability issues are addressed through training, support, or other means to improve the employee's ability to perform their role.

Overview

The company recognises that during your employment, your capability to carry out your role may deteriorate either due to job changes which you have failed to keep pace with or you may change (commonly due to health reasons) and you can no longer cope with the work. Initially, once a capability issue has been identified your line manager will provide you with support, training, and development opportunities to improve your skills and knowledge.

The procedure will be instigated where there is a ‘failure to carry out your duties to a satisfactory level due to a lack of ability, lack of training or lack of experience’.

Documentation and Records:

This policy requires managers to document all discussions, actions taken, and progress made in supporting you, the employee.

The Process

Initially, should there appear to be capability issues with an employee, the Company will instigate informal procedures whereby a discussion/job chat will be had between yourself and your Manager and the issue identified will be documented. In addition to this, future requirements will be detailed and the timescale for improvement noted. Managers are required to complete a ‘Job Chat’ form and save onto the employees Shorefield People record

The formal procedure will be instigated for more serious cases, or in any case where informal discussions as detailed above have not resulted in a satisfactory improvement. Managers - where the case is sufficiently serious to omit the informal stage, please contact HR for further guidance prior to any meeting with a member of staff

At each stage, consideration will be given to whether the unsatisfactory performance is related to a disability and if so, whether there are reasonable adjustments that could be made to the requirements of the job or other aspects of the working arrangements. If you have difficulty at any stage of the procedure because of a disability or wish to inform us of any medical condition you consider relevant, you should speak with your Manager.

Stage 1:

If no improvement has been made, an impartial investigation will be carried out into the matter and a decision made as to the requirement to hold a formal disciplinary hearing

If a hearing is to take place, you will receive a written invitation to this formal hearing which will clearly detail the required standards that are considered not to have been met. You will be given at least 48 hours’ notice of the hearing and have the right to be accompanied by either a trade union representative or a work colleague.

Following the hearing, if appropriate to do so, performance improvement plan notice will be given which will remain on your file for a period of 6 months (the review period). Targets for improvement and timescales will be clearly detailed in the outcome letter and checked off by your manager once/if attained.

Stage 2

At the end of the review period, if your manager is not satisfied with the improvement then a further formal hearing will be held and if appropriate a first written warning will be issued which will remain on your file for a period of 9 months. Targets for improvement and timescales will be detailed in a follow up letter and again checked off by your manager

Stage 3

At the end of 9 months, if your manager is not satisfied with the improvement then a further formal hearing) will be held and if appropriate a final written warning will be issued which will remain on your file for a period of 12 months. Final targets for improvement and timescales will be detailed in a follow up letter.

Stage 4

At the end of the review period, if your manager is not satisfied with the improvement then a further formal hearing will be held and if appropriate you may be dismissed.

Appeal

You have the right to appeal the outcome of any stage of the formal procedure and should you wish to do so, you should appeal in writing, clearly detailing the grounds for your appeal within 5 working days of the notification of the meeting decision. Further details will be advised in your decision letter.

Employees will not normally be dismissed for performance reasons without previous warnings. However, in serious cases of gross negligence/misconduct , or in any case involving an employee who has not yet completed their probationary period, dismissal without previous warnings may be appropriate depending on the issue and with prior consultation from the HR Manager.

This policy does not form part of the terms and conditions of your employment.

Employees’ Code of Conduct

Shorefield Holidays Limited expects the highest standards from its employees in carrying out its business whether that be during their regular working hours or out of hours activities that directly reflect on the organisation

▪ at office parties, office drinks events or other work-related social occasions or gatherings whether organised by the Company or by employees themselves

▪ at social occasions, lunches or gatherings organised by the Company’s customers or clients where the employee has been invited in their capacity as an employee of the Company

▪ at work-related conferences and training courses

▪ whilst the employee is working away on business on behalf of the Company

This Code of Conduct sets out those standards by which all employees are bound. It also refers to the relevant supporting policies in the Staff Handbook

It is the responsibility of all employees to familiarise themselves with the details of the Code and its guidance. If any employee has any queries or concern about how they should behave, they should contact HR.

The Code applies to all employees, seasonal staff and contractors.

The Purpose and Principles of the Code

This Code describes the principles by which Shorefield Holidays Limited expects its employees to conduct themselves and its business

It sets out the required standards of behaviour for its staff in carrying out this business.

The Code deals with a wide variety of issues and situations relating to workplace conduct and conduct outside of the workplace in attendance with the company or representing the company. This list is not intended to be exhaustive.

These principles are outlined in more detail in the Code below.

The Code

• We comply with all laws and regulations.

• We avoid conflicts of interest

• We respect the confidentiality of personal and corporate information in any situation.

• We promote diversity and equality and treat people fairly and with respect in all situations.

• We maintain a safe and healthy environment for people to work in and are proactive in managing our responsibilities to the environment.

Improper conduct or other unacceptable behaviour will not be tolerated and is a serious disciplinary matter. This includes, excessive drunkenness, the use of illegal drugs, unlawful or inappropriate discrimination or harassment, violence such as fighting or aggressive behaviour and serious verbal abuse or the use of other offensive or inappropriate language.

Under normal circumstances, the Company has no jurisdiction over employees outside working hours. However, if your activities outside work adversely affect the Company then they will become an issue. The following will result in disciplinary action:

• Bringing the name of the Company into disrepute

• Adverse publicity

• Actions that result in loss of faith in the Company, resulting in cancelled bookings

▪ Actions that result in loss of faith in the integrity of the individual (this includes harassment, bullying and any other inappropriate behaviour)

• Adverse comments relating to the Company on social media sites (Social Media Policy)

The detriment suffered by the Company will determine the level of misconduct and most suitable disciplinary stage considering the circumstances.

Your employment could be terminated if your actions cause extreme embarrassment or serious damage to the reputation or image of the Company.

Several of the principles and standards outlined in the Code are supported by more detailed specific policies in the staff handbook, on Shorefield People under policy compliance or for Managers, on the HR Hub within Teams

Zero Tolerance

While this Code gives guidance to employees in certain situations, there are specific areas where the Company has a policy of zero tolerance. These are:

• Unsafe, illegal or unethical working practices

• Violence and aggression

• Discrimination, bullying and harassment

• Bribery and corruption

• Retaliation or action against anyone who speaks up and, in good faith, reports a wrongdoing

Breaches of the Code

Any employee who is found to have breached these rules, or who otherwise brings the reputation of the Company into disrepute at an event will be subject to disciplinary action under the Company’s disciplinary procedure.

Depending on the circumstances of the case, such behaviour may be treated as gross misconduct (Refer to the disciplinary policy) and could render the employee liable to dismissal.

Any breach of the Code will be considered a disciplinary matter, which could result in disciplinary up to and including dismissal.

Where the employee’s off-duty conduct seriously undermines the trust and confidence that the Company has in the employee, whether at a work-related social occasion or otherwise, under the Company’s disciplinary procedure this could result in the employee’s dismissal.

For example, if the employee commits a criminal offence outside employment, the Company will examine whether there is an adverse connection between the criminal offence and the employee’s employment.

This Code of Conduct has been drawn up to provide guidance on conduct for staff of Shorefield Holidays Limited

For the avoidance of doubt, it is not a contractual document and the Company reserves the right to amend it at any time.

The Code will be subject to regular review, particularly in the light of new and relevant legislation.

Data Protection & Privacy Policy

DATA PROTECTION POLICY

Shorefield Holidays Ltd needs to collect and use certain types of information about employees, customers and suppliers who come into contact with Company. This personal information must be dealt with properly however it is collected, recorded and used – whether on paper, in a computer, or recorded on other material - and there are safeguards to ensure this in line with the Data Protection Act 2018.

The Company regards the lawful and correct treatment of personal information as very important and therefore ensures that personal information is treated lawfully and correctly.

To this end the Company fully endorses and adheres to the Principles of Data Protection, as detailed in the Data Protection Act 2018.

Principles:

The principles of the Data Protect Act 2018 require that personal information:

▪ shall be processed fairly and lawfully and shall not be processed unless specific conditions are met,

▪ shall be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes,

▪ shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed,

▪ shall be accurate and, where necessary, kept up to date,

▪ shall not be kept for longer than is necessary for that purpose or those purposes,

▪ shall be processed in accordance with the rights of data subjects under the Act,

▪ appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data,

▪ shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data

Criteria and Controls

The Company will, through appropriate management will apply strict application of criteria and controls to the following:

Observe fully conditions regarding the fair collection and use of information

▪ Meet the legal obligations to specify the purposes for which information is used

▪ Collect and process appropriate information, only to the extent that it is needed to fulfil operational needs or to comply with any legal requirements

▪ Ensure the quality of information used

▪ Apply strict checks to determine the length of time information is held

▪ Ensure that the rights of people about whom information is held, can be fully exercised under the Act. These include: the right to be informed that processing is being undertaken, the right of access to one’s personal information, the right to prevent processing in certain circumstances and the right to correct, rectify, block or erase information which is regarded as wrong information

▪ Take appropriate technical and organisational security measures to safeguard personal information,

▪ Ensure that personal information is not transferred abroad without suitable safeguards,

▪ Treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information,

▪ Set out clear procedures for responding to requests for information.

Data Protection Responsibilities

To ensure compliance with data protection laws and to safeguard personal information, the Company and its commits to the following:

▪ A designated Data Protection Officer (DPO) is in place Andrew Bowden holds this responsibility with Shorefield Holidays Ltd

▪ All individuals who manage or handle personal information understand that they are contractually responsible for following good data protection practices.

▪ All such individuals are given appropriate training to manage and handle personal information securely and lawfully.

▪ All such individuals are appropriately supervised in their data protection responsibilities.

▪ Any person wishing to make enquiries about the handling of personal information knows the correct procedure to follow.

▪ All queries regarding personal information are dealt with promptly and courteously.

▪ Methods and procedures for handling personal information are clearly documented and accessible to relevant staff.

▪ There are regular reviews and audits of how personal information is held, managed, and used.

▪ The methods of handling personal information are regularly assessed and evaluated to ensure ongoing compliance and effectiveness.

▪ Performance of staff in handling personal information is regularly assessed and evaluated.

▪ Breaches of the rules and procedures in this policy by a member of staff may lead to disciplinary action.

▪ Breaches of the rules and procedures in this policy by a Member are considered potential breaches of the Code of Conduct.

Roles and Responsibilities Table

Role

Director / ICT Manager (DPO)

Responsibilities

• Acts as the Company’s designated Data Protection Officer (DPO)

• Oversees implementation of this policy

• Ensures compliance with data protection legislation

• Conducts regular audits and reviews

• Provides advice and guidance on data protection issues

• Ensure staff complete data protection training

• Supervise staff handling personal information

Managers / Supervisors

All Staff

• Ensure compliance with procedures

• Support staff in addressing data protection queries or concerns

• Understand contractual responsibility to follow data protection best practices

• Complete mandatory data protection training

• Follow documented procedures for handling personal data

• Handle personal data securely, lawfully, and respectfully

• Promptly and courteously respond to data queries

• Participate in reviews, audits, and performance assessments

Role Responsibilities

Members

• Follow this policy and all data protection procedures

• Respect confidentiality and privacy when accessing personal information

• Understand that a breach may constitute a breach of the Code of Conduct

Policy Communication and Enforcement

Communication: This policy will be communicated via Shorefield People policy acceptance and must be acknowledged as part of the induction and any updates to this policy must be re-acknowledged by the same process

Enforcement: Non-compliance with this policy may result in disciplinary action, up to and including termination of employment.

Policy Updates

This policy will be reviewed regularly, as needed to reflect changes in Shorefield Holiday Ltd business and the Data Protection Act 2018.

Review

This policy will be reviewed annually or as needed to ensure its effectiveness and relevance.

Disciplinary Policy

The Company aims to ensure the safe and effective operation of the business and to promote fair treatment of individual employees. The following Disciplinary Procedure is designed not to punish staff but provides a framework to address any lapses in conduct, attendance or job performance and encourages individual employees to achieve and maintain an acceptable standard. This policy applies to all employees.

Minor faults will be dealt with informally, but where the matter is more serious the formal procedure will be used.

Informal procedure

Minor breaches of company standards, policies and procedures may result in an informal discussion with your Head of Department. The objective of the discussion is to help you to improve your conduct, attendance or job performance, without having to use a formal procedure. However, a note will be made by your Head of Department, of what was discussed and what improvements were agreed. Your Head of Department will then monitor your improvements over an agreed period. If you do not improve satisfactorily, or there are any further breaches of Company standards, policies or procedures, then the formal disciplinary procedure will be invoked.

At these discussions a member of the HR Department may be present or replace the Head of Department at any time.

Formal procedure

Investigation

If it becomes necessary to formally address issues regarding your conduct, attendance or job performance, the matter will firstly be investigated by an impartial (supervisory level or higher) member of staff member and/or the HR Department.

This investigation will be carried out quickly and thoroughly. Confidentiality will be maintained, as far as is reasonably possible, during the investigation and throughout the disciplinary process, should this be activated.

Under certain circumstances, including but not limited to harassment, bullying, theft and violence, Shorefield Holidays Limited may decide to suspend you on full pay, based on your contracted hours, while the matter is being investigated. This is not a disciplinary sanction, but a way of ensuring that a full review of the circumstances can take place as effectively as possible.

Disciplinary Meeting

If, after an investigation has been carried out, it is considered that there is a case to answer, you will be notified in writing of the nature of the complaint against you. At this stage you will be made aware of the level of seriousness of the case and the possible disciplinary action that may ultimately be taken. You will be provided with details of any supporting evidence that may be available. You will also be notified of the date and time you are required to attend a disciplinary meeting. You will be advised of your right to be accompanied at this meeting by a work colleague.

Dependant on the level of seriousness of the case, the meeting will be conducted by the appropriate Head of Department as shown in the Disciplinary authorisation Level Chart (available from HR)

At this meeting the nature of the breach of Company standards will be made clear to you and you will be given the opportunity to state your case. If any additional issues arise during this meeting, an adjournment may take place to allow for further investigation.

During the disciplinary process, and during any subsequent appeal, you will be provided with copies of notes, witness statements or interview transcripts as soon as they become available.

Disciplinary Outcomes

If, at the conclusion of a disciplinary meeting, it is decided that there has been a breach of Company standards, formal disciplinary action will be taken.

Stage 1 – Verbal Warning

If your conduct, or job performance is unsatisfactory or there is no improvement after an informal warning has been issued, you will be given a formal VERBAL WARNING, a note of which will be held on your personnel file. You will also be reminded that if there is no improvement within 6 months, further disciplinary action will be taken.

Stage 2 – First Written Warning

If the breach of Company standards is more serious, or there is no improvement in your conduct, or job performance, or another breach of Company standard occurs, you will receive a FIRST WRITTEN WARNING. This will include the reason for the warning, give details of how you should improve and remind you that if there is no improvement within 9 months, further disciplinary action will be taken.

Stage 3 – Final Written Warning

If the breach of Company standards is very serious, or there is still no improvement in your conduct, or job performance or another breach of Company standard occurs a FINAL WRITTEN WARNING will be given. This will include the reason for the warning, giving details of how you should improve, and remind you that if there is no improvement within 12 months, you may be DISMISSED.

When you are issued with a warning, a copy of the warning will be kept in your personnel file. If your conduct or job performance has reached an acceptable level after the specified period, the warning will be disregarded for disciplinary purposes, but will be kept on your personnel file.

Stage 4 – Dismissal

If there is no satisfactory improvement in your conduct, or job performance, or if a further breach of Company standards occurs, you will be DISMISSED. You will be informed in writing of the decision to dismiss you, given details of the reason for the dismissal, your termination date, the appropriate period of notice or amount of pay in lieu of notice, your right of appeal and details of the appeal process.

A decision to dismiss will normally be taken by a Director and dismissal will only be applied when sound judgement indicates no reasonable alternative.

If you are dismissed under this policy your employment will terminate on the date specified in writing. Your employment will NOT be suspended pending the outcome of any appeal procedure. Should an appeal reverse the decision to dismiss you, you will be reinstated with no break in service and any monies owing to you will be paid.

Any of the above stages of disciplinary action may be omitted, depending on the seriousness of the misconduct.

Serious Misconduct

The following are some examples of serious misconduct, but the list is not exhaustive:

▪ Poor performance

▪ Poor timekeeping (repeated lateness or early leaving)

▪ Unauthorised and unreasonable absence from place of work

▪ Disruptive behaviour

▪ Smoking in any other than designated areas (see also Gross misconduct)

▪ Failure to maintain the required standard of dress and/or behaviour

▪ Contravention of safety and hygiene requirements

▪ Failure to follow the Company rules and procedures

▪ Failure to use/maintain Company equipment correctly

▪ Failure to carry out a reasonable instruction from a more senior member of Management

Gross Misconduct

If you are found guilty of gross misconduct Shorefield Holidays Limited is entitled to summarily dismiss you. This means that you will be dismissed with immediate effect, without notice. Gross misconduct is any deliberate act by you that is detrimental to the good conduct of the Company’s business.

Examples of gross misconduct include, but the list is not limited to:

▪ Theft from the Company, its employees, agents, customers or guests

▪ Fraud or deliberate falsification of records

▪ Receiving or accepting a gift or benefit from a supplier, customer, guest or employee which could be construed as a bribe or corrupt reward

▪ Actions constituting a criminal offence

▪ Misuse, abuse or deliberate damage to company property, including intellectual property, or that of other employees

▪ The supply or possession of alcohol or illegal drugs, or, in our opinion (the Company’s/Manager etc) being under the influence of alcohol or illegal drugs on the company’s premises or during working hours.

▪ Physical violence, actual or threatened or abusive behaviour

▪ Serious act of insubordination / or the deliberate disregard or refusal to carry out a reasonable instruction by a more senior member of Management

▪ Inappropriate use of internet, intranet and e-mail facilities

▪ Harassment or discrimination on any grounds

▪ Disclosure of confidential information

▪ Deliberate disregard or refusal to follow Company rules and procedures

▪ Deliberate disregard or refusal to follow Company procedures for regulated business, eg the sale of insurance or the sale of holiday homes

▪ Smoking in a non-designated area where this is likely to cause a risk to the health or safety of others

▪ Serious or repeated negligent acts in the performance of your duties

▪ Giving false or misleading information to the Company

▪ Persistent absence from the workplace without permission or reasonable excuse

▪ Covert recording of meetings

▪ Covert photography or videoing

Disciplinary proceedings shall not be affected or interrupted by the employee invoking the grievance procedure.

Conduct outside normal duties

Some conduct outside an employee’s normal duties may prejudice the employee / employer relationship and lead to disciplinary investigation and action. An example would be conviction of a serious criminal offence or failure to follow any policy or procedure.

Criminal Conviction/Conduct Outside Work

If you are convicted on a criminal offence of any nature (including driving convictions) you must inform your Head of Department or HR immediately.

If you commit a criminal offence during your time off work to attend a sporting or other special event, for example being drunk and disorderly in a public place or being involved in football hooliganism, the Company reserves the right to take disciplinary action against you, even though the conduct has occurred outside work and in your own time. Depending on the circumstances of the case, it may amount to gross misconduct and could result in summary dismissal.

Appeals Procedure

You have the right to appeal against any disciplinary action which is taken against you.

Your appeal must be made in writing to the HR Manager as stated on the warning letter, within 5 working days of the decision being communicated to you in writing and you should detail your reason(s) for appealing against the disciplinary action.

The appropriate person as specified on the disciplinary authorisation level chart, who will not have had any previous involvement in your case, will investigate your appeal. The appeal will be considered within 5 working days of the Company receiving your appeal letter. If it is anticipated that the appeal process will take longer than 5 working days from receipt of your appeal letter you will be informed of this and of the expected timescale.

If it is necessary to hold an appeal meeting, you will be notified of this in writing, and advised of your right to be accompanied at this meeting by a work colleague or a trade union representative. If additional issues or new evidence arise during this meeting, an adjournment may take place to allow for these to be investigated.

After considering your appeal, a decision may be taken to uphold the disciplinary action which has been taken against you, to reduce it or to overturn the findings of the disciplinary meeting. A more severe form of disciplinary action cannot be imposed. You will be informed of the outcome of the appeal and the reasons for the decision in writing, as soon as possible. The decision which is reached is final.

The employee may withdraw an appeal notice in writing at any time to the appropriate person.

Records

All records relating to disciplinary action will be kept in accordance with the provisions of the Data Protection Act 2018. This procedure does not form part of your terms and conditions of employment.

Disciplinary Process

Issue/Breach

Investigation instigated by Line Manager

Intial investigation/ fact finding performed by a nominated internal investigating officer Manager with support from HR.

FINDINGS PRESENTED TO MANAGER TO DECIDE INFORMAL/FORMAL

Informal Proceedure

- fact finding excercise suggests informal route can be followed

No Further Action

Informal notes/evidence given back to Instigating Manager for no further action or Job Chat (template can be found on the HR Hub under discplinary)

Formal Proceedure

DECIDED BY MANAGER

Investigator to invite employee to Formal Meeting informing employee of intent to proceed with the formal process following the fact find by the Investigating Officer -

Requirements: 72 hours notice of this meeting and right to be accompanied MUST HAVE HR PRESENT

Formal meeting

Conducted by investigating officer/manager - 5 working days notice and right to be accompaniedPURPOSE - Informing employee of progressing formally , employee has the right to be accompanied by TU Rep or Collegue from this point

Investigation report (template can be found on HR Hub - discplinary) to be written and submitted to Instigating Manager

Proceed to Hearing Manager to take back ownership from this point

Hearing Bundle to be created including the completed investiagtion report and any evidence that has come as a result of the fact find and subsequent interviews

Equality, Diversity & Inclusion Policy

Shorefield Holidays Limited is committed to encouraging equality, diversity and inclusion among our workforce, and eliminating unlawful discrimination. The company is committed to the promotion of equal opportunities of all employees and applicants, regardless of sex, age, gender, marital/civil partnership status, race, creed, colour, ethnic origin, religion or disability. This principle will apply in respect of all terms and conditions of employment, including recruitment, training, conduct, promotion and redundancy.

The Company takes the issue of equal opportunities seriously and will not accept discrimination against employees. The Company may discriminate against an individual where they are already an employee, by preventing them from becoming a customer or a supplier / contractor or vice versa as the Company may wish to have only one type of relationship with the individual.

Anti-social behaviour such as racial harassment, sexual harassment (please view separate policy), or bullying and intimidation in any form, whether verbal, written or physical, using any platform of media will not be tolerated and will be dealt with under the disciplinary procedure. Employees may raise issues relating to this by using the harassment procedure.

If any employee has a complaint that he or she feels they have suffered unequal treatment, discrimination or violence in any way, they should use the Company’s grievance procedure and/or the police in instances such as physical harm

No employee will be penalised for raising a complaint of unfair treatment unless it is untrue and made in maliciously.

In the first instance a complaint should be raised to the employee’s Head of Department, or to the HR Manager, who will give impartial, confidential advice.

At Shorefield Holidays Limited we recognise that in addition to the laws that cover equality issues that we have a responsibility to meet, there are business benefits from having a diverse and inclusive workforce, that include increased creativity and innovation.

Just as importantly however, we believe that by treating everyone fairly and honestly we shall be a respected business that people want to be associated with and work for. It should be evident from our strategies, policies and procedures and our culture and in the way that we deal with people that come into contact with our business, we strongly believe in equal opportunities and the benefits of diversity.

Our commitments

Shorefield Holidays Limited commits to:

Encourage equality, diversity and inclusion in the workplace as they are good practice and make business sense.

Create a working environment free of bullying, harassment, victimisation and unlawful discrimination, promoting dignity and respect for all, and where individual differences and the contributions of all staff are recognised and valued. This commitment includes training managers and all other employees about their rights and responsibilities under the equality, diversity and inclusion policy. Responsibilities include staff conducting themselves to help the organisation provide equal opportunities in employment, and prevent bullying, harassment, victimisation and unlawful discrimination.

All staff should understand they, as well as the company, can be held liable for acts of bullying, harassment, victimisation and unlawful discrimination, in the course of their employment, against fellow employees, customers, suppliers and the public.

Take seriously complaints of bullying, harassment, victimisation and unlawful discrimination by fellow employees, customers, suppliers, visitors, the public and any others in the course of the organisation's work activities.

Such acts will be dealt with as misconduct under the organisation's grievance or disciplinary procedures, and appropriate action will be taken. Particularly serious complaints could amount to gross misconduct and lead to dismissal without notice.

Further, sexual harassment may amount to both an employment rights matter and a criminal matter, such as in sexual assault allegations. In addition, harassment under the Protection from Harassment Act 1997 – which is not limited to circumstances where harassment relates to a protected characteristic – is a criminal offence.

Make opportunities for training, development and progress available to all staff, who will be helped and encouraged to develop their full potential, so their talents and resources can be fully utilised to maximise the efficiency of the organisation.

Make decisions concerning staff based on merit (apart from in any necessary and limited exemptions and exceptions allowed under the Equality Act).

Review employment practices and procedures when necessary to ensure fairness, and also update them and the policy to take account of changes in the law.

Monitor the make-up of the workforce regarding information such as age, sex, ethnic background, sexual orientation, religion or belief, and disability in encouraging equality, diversity and inclusion, and in meeting the aims and commitments set out in the equality, diversity and inclusion policy.

Monitoring will also include assessing how the equality, diversity and inclusion policy, and any supporting action plan, are working in practice, reviewing them annually, and considering and taking action to address any issues.

Flexible Working Policy

Shorefield Holidays Limited recognises that a sensible balance between employees’ personal and working lives is vital. This is because of the potential impact it can have on employees’ health and wellbeing and their effectiveness in and out of work.

Employees have a statutory right to request to work flexibly and to have their flexible working application dealt with in a reasonable manner. You have the right to request flexible working under this policy from day one of your employment with the company.

You can make up to 2 applications for flexible working in any 12-month period

The Company will consider any requests for a change to working patterns or arrangements from any employee.

The need for flexible working will be balanced with the ability to meet organisational objectives and provide a service without adversely impacting upon the operation, colleagues or customers. Possible requests could include, but are not limited to, working reduced hours, changing when hours are worked, compressing contracted hours into fewer working days a week, job sharing, working from home or another location and extended leave.

Employees should initially speak to their managers about their situation and then put such requests in writing to them, including details of the reason for their application, the potential effects this may have upon the business, and suggestions for how these effects may be dealt with. A meeting with the employee will be arranged within 28 days of them receiving this letter and a written decision including the reasoning behind it will be provided to the employee within 14 days of this meeting. If the Company accepts the request and does not deem a meeting necessary, the written decision will be provided within 28 days of receiving the request letter. The only exception to these timings will be if the letter is received in the absence of the manager who would normally deal with this, in which case reasonable timings will be agreed between employer and employee.

The Company will not consider any change that would contravene the law e.g. the Working Time Directive.

Concerns regarding this process should be raised with the HR Department.

If the employee chooses to appeal this decision, they should put it in writing to the HR Manager within 14 days of receiving the written decision from the Company, stating their reasons for appealing it. A meeting to discuss this will be held within 14 days of receiving the appeal letter, and a further written decision will be provided to the employee within 14 days of the appeal meeting.

Where your request is accepted, unless otherwise agreed, it constitutes a permanent change to your terms and conditions of employment. This means you do not have the right to revert to your previous pattern of working at a future date.

If the Company is uncertain of the potential effects of a change to working arrangements, it may choose to trial it for a limited period to allow for proper consideration. In this case a decision will be given at a time agreed between employer and employee.

Grounds for Refusal

The Company may refuse your flexible working application on one or more of the following business grounds (however this list is not exhaustive):

▪ The burden of additional costs

▪ The detrimental effect it would have on the Company’s ability to meet customer demand

▪ The Company’s inability to reorganise work amongst existing staff

▪ The Company’s inability to recruit additional staff

▪ The detrimental impact it would have on quality

▪ The detrimental impact it would have on performance

▪ The insufficiency of work available during the period when you propose to work

▪ The Company’s planned structural changes

In refusing an application the Company will provide details relating to why the ground applies in the circumstances. Each request for flexible working will be dealt with individually, considering the likely effects the changes will have on the Company, the work of the department in which you are employed, your work colleagues and the circumstances of the case. This means that if the Company agrees to one employee’s request, this does not set a precedent or create a right for another employee to be granted the same or a similar change to their work pattern. For example, having approved one flexible working request, this may mean that the business context has changed, and this may be considered when considering a second request from another employee against the above business grounds.

Working from Home

Working from home is not permitted unless prior approval has been given by the Finance Director.

Flexible Working Procedure

Shorefield Holidays Limited encourages staff to consider flexible working arrangements. The organisation recognises that a better work-life balance can improve employee motivation, performance and productivity, and reduce stress. Therefore the organisation wants to support its employees to achieve a better balance between work and their other priorities, such as caring responsibilities, leisure activities, further learning and other interests.

The organisation is committed to agreeing flexible working arrangements, provided that the needs and objectives of both the organisation and the employee can be met.

It is the organisation's policy to encourage open discussion with employees. If an employee thinks they may benefit from flexible working, they can either:

▪ Contact the HR department or line manager to arrange an informal discussion to talk about the options.

▪ Submit a flexible working request.

This policy does not form part of the employment contract, and can be amended at any time.

What is flexible working?

Flexible working is any type of working arrangement that gives some degree of flexibility on how long, where and when an employee works.

For example:

▪ Annualised hours

▪ Compressed hours

▪ Flexitime

▪ Hybrid working

▪ Job sharing

▪ Part-time working

▪ Staggered hours

▪ Working from home

These examples are considered to be the typical arrangements that employees will request. However, the organisation recognises that there may be alternatives or a combination of options which are suitable to both the organisation and the employee

Eligibility

All employees have a statutory right to request flexible working from the first day of employment.

Our approach to flexible working

The organisation is committed to providing a range of appropriate working patterns.

There are many different types of flexible working. While some might not be practical for every job, it's likely other types will work. The organisation commits to look at what's possible.

Where a flexible working arrangement is requested, the organisation will take into account a number of criteria. This includes:

▪ the costs associated with the proposed arrangement

▪ the effect of the proposed arrangement on other staff

▪ the need for, and effect on, supervision

▪ the existing structure of the department

▪ the availability of staff resources

▪ details of the tasks specific to the role

▪ the workload of the role

▪ whether it is a request for a reasonable adjustment related to a disability

▪ health and safety issues

The organisation is committed to agreeing any flexible working arrangements, provided that the needs and objectives of both the organisation and the employee can be met.

The procedure for flexible working will explain in more detail the process that the organisation recognises, and will follow upon all flexible working request submission.

Where flexible working practices are agreed as a permanent change, any variation to the employee's terms and conditions will be put in writing. Written confirmation of the changes will be sent to the employee within one month of the change being agreed.

If the employee has any questions or concerns they should contact the HR department.

Right to appeal a decision

An employee has the right to appeal the decision if their request is refused or is only agreed in part. Appeals must be submitted within 5 working days of being notified of a decision on their request. This should be done in writing and clearly state the reasons for their appeal.

Change of employee's contract

Where flexible working practices are agreed as a permanent change, any variation to the employee's terms and conditions will be put in writing. Written confirmation of the changes will be sent to the employee within one month of the change being agreed.

For further information or assistance please contact the HR department

Grievance Policy

Shorefield Holidays Limited recognises that from time to time employees may wish to seek redress for grievances relating to their employment. The Company policy is to encourage free communication between employees and their Heads of Department to ensure that questions and problems arising during their employment can be aired and where possible resolved quickly and to the satisfaction of all concerned. This policy applies to all Employees

Shorefield Holidays Limited and will be treated fairly with appropriate confidentiality

Informal procedure

Many work-place problems can be resolved quickly and easily by taking informal action. If appropriate, you should first raise your grievance on an informal basis with your Head of Department. They will listen carefully to what you have to say and will discuss the matter thoroughly with you.

Your Head of Department may want to investigate your complaint further and you will be advised if this is the case.

After your grievance has been fully investigated, they will let you know that the matter has been dealt with and what action, if any, has been taken. If it is not appropriate to raise the grievance with your Head of Department, or in the absence of the Head of Department, you should raise the grievance with a member of the HR department.

At these discussions a member of the HR Department may be present or replace the Head of Department at any time.

Mediation

Mediation involves the use of an impartial experienced person to mediate on the grievance and it can take place at any stage of the grievance process including completion should this be necessary. The decision on whether to enter into mediation is initiated by the manager but requires the agreement and participation of both parties. Where mediation is initiated, the formal procedure maybe temporarily halted.

Formal procedure

If it is not appropriate to raise your grievance informally, or your grievance has not been resolved to your satisfaction through informal action, you should use the formal grievance procedure. Before raising a formal grievance, employees are expected to , wherever possible, to make reasonable and genuine attempts to resolves issues informally and they need to be clear about the resolution they are seeking

Stage 1

You should put your grievance in writing and send it to your Head of Department/HR Department. If your grievance involves your Head of Department then you should send your grievance directly to the HR Department.

Within 5 working days of receiving your complaint, your Head of Department/HR representative will arrange a meeting with you to discuss your grievance. They will listen carefully to what you have to say and will discuss the matter thoroughly with you. Your Head of Department/HR representative may want to investigate your complaint further and you will be advised if this is the case. If it is anticipated that it will take longer than the 5 days to fully investigate, you will be informed of this.

After your grievance has been fully investigated, they will advise you that the matter has been dealt with and what action if any, has been taken. This response will be given to you in writing, within 5 working days of the meeting. If it is

anticipated that the response will take longer than 5 working days from the meeting you will be informed of this and of the expected timescale.

Stage 2

If your grievance is still not resolved or you are dissatisfied with the handling of your grievance at Stage 1, you should raise your grievance in writing to the HR Manager within 5 working days.

Within 5 working days of receiving your written complaint, the HR Manager will arrange a meeting with you to discuss your grievance. They will listen carefully to what you have to say and will discuss the matter thoroughly with you.

The HR Manager may want to investigate your complaint further and you will be advised if this is the case. After your grievance has been fully investigated, they will advise you that the matter has been dealt with and what action if any, has been taken. This response will be given to you in writing, within 5 working days of the meeting. If it is anticipated that the investigation and/or response will take longer than 5 working days, you will be informed of this and of the expected timescale.

During all stages of the formal grievance procedure you will be provided with copies of notes as soon as they become available. At any stage, the employee raising the grievance has the right to be accompanied by a work colleague and to retract their grievance at any time if a solution is agreed

Appeals Procedure

You have the right to appeal against the decision made at stage 2 of the grievance procedure

Your appeal must be made in writing to the HR Manager, within 5 working days of the decision being communicated to you in writing and you should detail your reason(s) for appealing against the disciplinary action.

The appropriate person as specified on the authorisation level chart, who will not have had any previous involvement in your case, will investigate your appeal. The appeal will be considered within 5 working days of the Company receiving your appeal letter. If it is anticipated that the appeal process will take longer than 5 working days from receipt of your appeal letter you will be informed of this and of the expected timescale.

If it is necessary to hold an appeal meeting, you will be notified of this in writing, and advised of your right to be accompanied at this meeting by a work colleague or a trade union representative. If additional issues or new evidence arise during this meeting, an adjournment may take place to allow for these to be investigated.

After considering your appeal, a decision may be taken to uphold the decision which has been made, to reduce it or to overturn the findings of the grievance. A more severe form of outcome/action cannot be imposed. You will be informed of the outcome of the appeal and the reasons for the decision in writing, as soon as possible. The decision which is reached is final.

The employee may withdraw an appeal notice in writing at any time to the appropriate person.

Records

All records relating to the grievance will be kept in accordance with the provisions of the Data Protection Act 2018.

This procedure does not form part of your terms and conditions of employment.

Grievance Procedure

Grievance Raised

Informal -

Discuss and facilitate mediation if appropriate

Appropriately resolved by both partiesconcluded and communications sent

If informal resolution is not appropriate or not resolved to satisfaction following demonstrated reasonable and genuine attempts then the formal route should be used with a clear resolution indicated from the complainant

Stage 1: Grievance in writing to HOD. Within 5 working days employee will be invited to discuss the grievance and the manager may wish to action an investigation. Once this has been concluded, the employee will be advised of any action taken

Appropriately resolved by both parties –concluded and communications sent

Appeal: You have the right of appeal the decision made at stage 2 and made in writing to the HR Manager. An appropriate person as specified in the authorisation level chart will consider/ the appeal within 5 working days where possible and any communications will be given in writing . Once a decision is made this is final

Stage 2: Grievance still not resolved or employee dissatisfied with stage 1, escalate to HR Manager. Within 5 working days HR will discuss the matter with the employee and advised of next steps. Once this is concluded the employee will be advised of any action taken in writing.

Written confirmation sent informing employee whether the original decision was upheld or amended along with the reason for the decision

AGAIN This decision is final

Raising a Grievance

If you have a grievance, you should raise this with your line manager in the first instance. If this is not appropriate, you should speak to the HR Team.

Wherever possible, we will deal with your grievance informally and promptly. If you are not satisfied with the action that we have taken or if we are unable to resolve the issue, you can raise a formal grievance. To do this, you should put the grievance in writing and send this to your line manager or other appropriate manager.

Formal grievance

If the matter is serious or you wish to raise it formally you should put the grievance in writing to your manager. You should keep to the facts and avoid language that is insulting or abusive. If your grievance is against your manager and you feel unable to approach them, you should raise it with the Hr team.

Grievance Meeting

The manager will arrange a meeting with you, usually within 5 days, to discuss your grievance in more detail. You can be accompanied by a colleague or trade union representative at the grievance meeting if you make a reasonable request.

At the grievance meeting, the manager will ask you to explain your concerns in more detail and to answer any questions about them. If possible, the manager will suggest a solution at the meeting but, sometimes, further investigation will be necessary. In this case, the manager will adjourn the meeting until the investigation is complete. An estimated timescale will be provided by the manager

Following the meeting, the manager will confirm in writing the action that the organisation has decided to take.

Appeal Meeting

If you are not satisfied with the proposed action, you can appeal. You must submit the appeal in writing within 5 days of receiving the letter confirming the outcome of your grievance. You should state why you wish to appeal. You will be invited to an appeal hearing, usually within 5 days. Wherever possible, this will be held by a more senior manager than the one who chaired the grievance meeting. You have the same right to be accompanied at this meeting.

The manager will confirm the outcome of the appeal hearing in writing, usually within 24 hours.

This decision is final

Privacy Notice

WHAT IS A PRIVACY NOTICE

This privacy notice is intended for both current and former employees, workers and contractors. As a company, Shorefield Holidays ltd must legally provide a privacy notice under the UK's Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR) if they process personal data. Individuals have a legal right to be informed about how their personal data is being collected and used, and the privacy notice is the primary way we as a company fulfil this transparency requirement.

We respect your privacy and are committed to protecting your personal information, which we call “personal data”. This privacy notice will tell you how we look after your personal data and about your privacy rights.

This notice does not form part of any contract. It supplements any other notices and is not intended to override them.

WHO WE ARE

Data Controller (Park Owner) (referred to as “we/us/our”)

Shorefield Holidays Limited

Name or title of Data Protection Manager: Andrew Bowden, Director / ICT Manager

Address: Shorefield Rd, Milford-on-Sea, Lymington, Hampshire SO41 0LH

Telephone: 01590 648300

Email: yourdata@shorefield.co.uk

CHANGES

This version was last updated on 25/5/18 and historic versions can be obtained by contacting us at the email address above.

It is important that the personal data we hold about you is accurate and current. Please keep us informed of any changes.

HOW WE COLLECT YOUR PERSONAL DATA

We collect personal data through application and recruitment processes, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties. (see table on next page)

We may also receive personal data about you from third parties and public sources, including:

Who When

Former employers and other referees

Credit reference agencies

Disclosure & Barring Service (DBS)

We may ask you for permission to take a reference from former employers and other referees as a condition of a contract or offer to you.

We may make a credit reference check on our contractors.

We may require you to apply for a DBS check. We do this for certain positions within the Company, and for employees supplied with accommodated by the Company on our parks.

We will collect additional personal information during job-related activities throughout the period of you working for us.

WHAT PERSONAL DATA DO WE COLLECT?

Personal Data

Personal contact details such as name, title, addresses, telephone numbers and personal email addresses

Date of birth

Gender

Marital status

Next of kin and emergency contact information

National Insurance Number

Bank account details, payroll records and tax status information

Pay, holiday and benefits information

Start date

Location of employment or workplace

Copy of driving licence

Recruitment information including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process

Employment records including job titles, work history, training records and professional memberships

History of pay and benefits received

Performance information

Disciplinary and grievance information

CCTV footage and other information obtained through electronic means such as swipe-card records, where used

Information about your use of our information and communication systems

Photographs

Automatic Number Plate Recognition

Employee Leisure Membership card swipes for discounts in our facilities

SENSITIVE PERSONAL DATA

We may also collect, store and use the following categories of more sensitive personal information

Information about your race or ethnicity

Trade union membership

Information about your health, including any medical condition, health and sickness records

Genetic information and biometric data, such as drug test results

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. In each case we may rely on three reasons to do so. These are:

(a) The performance of a contract with you.

(b) Because it is necessary to comply with a legal obligation.

(c) Because it is necessary for our legitimate interests.

These three reasons for using your personal data overlap and there may more than one ground to justify our use of your personal information on any occasion.

Purpose/Activity

Making a decision about your appointment or recruitment

Deciding the terms on which you work for us

Checking you are legally entitled to work in the UK

Lawful basis for processing (see above)

a, b & c

a, b & c

a, b & c

Paying you and deducting any tax or national insurance due a, b & c

Administering our contract

a, b & c

Business management and planning including accounting and auditing c

Managing performance including carrying out performance reviews and setting targets

a, b & c

Basis of legitimate interest, where applicable

Making decisions about pay reviews and other benefits.

Assessing qualifications for a job or task including decisions about promotion

Gathering evidence for possible grievance or disciplinary hearings

a, b & c

To appoint and retain people who can help us develop and grow our business. To treat you fairly.

To appoint and retain people who can help us develop and grow our business. To treat you fairly.

To appoint and retain people who are legally entitled to work in the UK.

To comply with the law.

To retain people who can help us develop and grow our business. To treat you fairly. To ensure that you meet your obligations to us and that we can address any situation in which you do not.

To help us develop and grow our business.

To retain people who can help us develop and grow our business, to treat you fairly. To ensure that you meet your obligations to us and that we can address any situation in which you do not.

To retain people who can help us develop and grow our business. To treat you fairly.

a, b & c To appoint and retain people who can help us develop and grow our business. To treat you fairly.

a, b & c

To retain people who can help us develop and grow our business. To treat you fairly. To ensure that you and your work colleagues meet your obligations to us and that we can address any situation in which you or they do not.

Purpose/Activity

Making decisions about your continued employment or engagement

Lawful basis for processing Basis of legitimate interest, where applicable

a, b & c

Education, training and development requirements

Dealing with legal disputes involving you or others connected to our business, including accidents at work

Ascertaining your fitness to work

Managing sickness absence

Complying with health and safety obligations

To prevent fraud

To monitor your use of our information and communication systems to ensure compliance with our IT policies

To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution

To conduct data analytics studies to review and better understand employee retention and attrition rates

Equal employee monitoring

Providing the benefits to employees which are listed below

a, b & c

b & c

a, b & c

a, b & c

Ensure that we retain people who can help us develop and grow our business, treat you fairly and ensure that you meet your obligations to us and that we can address any situation in which you do not.

Ensure that we equip you to help us develop and grow our business.

To protect our legitimate interests and those of others in legal disputes.

Appoint and retain people who can help us develop and grow our business. To treat you fairly. To ensure that you meet your obligations to us and that we can address any situation in which you do not.

Appoint and retain people who can help us develop and grow our business. To treat you fairly. To ensure that you meet your obligations to us and that we can address any situation in which you do not.

a, b & c To keep you and your colleagues healthy and safe at work.

a, b & c Prevent fraud and to take appropriate action if it takes place, including action against anyone responsible.

a, b & c

Ensure that you meet your obligations to us and that we can address any situation in which you do not. To ensure that we comply with the law.

a, b & c Keep out network and information secure and to take appropriate action if it is breached, including action against anyone responsible.

c To retain people who can help us develop and grow our business.

a, b & c Ensure meaningful equal opportunity monitoring and reporting.

a, b & c

Appoint and retain people who can help us develop and grow our business. To meet our obligations to you.

Relevant benefits

1. To give you information about our pension scheme and to administer your membership if you join.

2. To give you information about, and to administer discounts you may receive when using our facilities.

3. To give you information about the Your Shorefield reward portal, and to administer your membership of this if you join.

4. To give you information about your membership of our bar and leisure complexes, and to administer your membership

HOW WE USE YOUR SENSITIVE PERSONAL DATA

Sensitive personal data

Information relating to absence, which may include sickness absence or family related leave

Information about your physical or mental health or disability

Information about your race or ethnicity

Information about criminal convictions and offences

Lawful basis for processing

a, b & c

a, b & c

a, b & c

a, b & c

Any other basis of legitimate interest, where applicable

To comply with employment or other laws. To ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.

Ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits

Ensure meaningful equal opportunity monitoring and reporting.

Help us make a fair decision about your appointment or recruitment or about your continued employment or engagement, where the information is relevant.

Use when necessary in relation to legal claims.

Use when necessary to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

We do not need your consent to use your sensitive personal data in these ways. However, in limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

CHANGE OF PURPOSE

Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

However, if we need to use your personal data for a new purpose and the law allows us to do so, we will notify you and explain the legal basis for our actions.

IF YOU FAIL TO PROVIDE PERSONAL DATA

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with third parties to help us run our business or carry out our obligations to you:

Name

Service providers for IT and system administration, Payroll, Pension & other employment benefits

Our professional advisers including bankers, auditors, insurers & solicitors

HM Revenue & Customs, regulators and other authorities

Lawful basis for processing including basis of legitimate interest

Performance of a contract with you, necessary for our legitimate interests performing the contract, using your data as we have described in this notice).

Necessary for our legitimate interests (complying with our legal obligations, helping us develop and grow our business).

Necessary for our legitimate interests (complying with our legal obligations).

Names of third parties, where relevant

• Advanced (HR & Payroll software providers)

• Standard Life (pension provider)

• HSBC (Bank)

• NFU (Insurers)

• Francis Clark Princecroft Willis (Auditors)

• Pilgrim Law (Solicitors)

Where required

We may also share your personal data with any third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

We do not transfer your data outside the European Economic Area.

AUTOMATED DECISION MAKING

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We do not envisage that any decisions will be taken about you using automated means. We will notify you in writing if this position changes.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

HOW LONG WILL WE USE YOUR PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

You can ask us about the retention periods for different aspects of your personal data by contacting our Data Protection Manager.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

You have the right to:

▪ Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

▪ Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

▪ Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

▪ Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

▪ Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

▪ Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

▪ Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

No fee usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) (www.ico.org.uk). We would appreciate the chance to deal with your concerns first.

Recruitment Policy

Overview

Shorefield Holidays Limited is a rapidly growing organisation that constantly needs to attract new recruits to fill new positions and to replace leavers. This policy covers both our external and internal recruitment. It is designed to ensure that our recruitment is fair and lawful and that it leads to the right people being appointed to the right role

We are an inclusive organisation which encourages applications from across society. We’re committed to building a workforce of capable and committed people from all walks of life As a customer focused organisation, our aim is to recruit people of all ages to ensure we select the best person for each position. Where we are unable to source suitable applicants locally, we actively encourage applicants from overseas.

We do all we can during our recruitment process to make sure that job applicants (people who send us job applications), job candidates (those whose applications we take through to subsequent stages) and general job seekers are not disadvantaged in connection with a protected characteristic such as age, sex, race or disability

This policy does not form any part of you contract and we may update it at any time

You should read and engage this policy alongside the Company’s policies on Equal Opportunities and Data Protection to ensure all procedures adhere to these during the process.

Defining the Role

When we need to recruit, we will carefully consider what the role involves. We will review and may update an existing job specification to make sure that it properly reflects the day-to-day duties and responsibilities involved.

We will list the qualifications, skills, attributes, knowledge and expertise that we are looking for (‘the person specification’).

If we think that the role could work as a part-time, job-share or other type of flexible working arrangement, we will take that into account when we are recruiting.

Our Job Adverts

Job adverts are prepared by a member of HR. Department Managers have a duty to inform HR of any necessary changes or certain requirements where appropriate. Our job adverts comply with equality law. In particular, we don’t use wording that could discourage applications from some groups in society.

We may decide to advertise a vacancy internally and externally. When we advertise internally, we make sure that employees who are absent because of long-term sickness or maternity leave for example, are told about the vacancy and are given the same opportunity as their colleagues to apply. We advertise vacancies in places and recruitment websites such as Indeed etc that are accessible to all potentially interested job applicants.

Your job application

If you need information such as an application form, job specification or person specification in an accessible format (large print, for example), ask us. As long as your request is reasonable, we will do what we can to help

We will not ask you to disclose details of criminal convictions unless that would be justified based on the role you are applying for. If we do ask for this disclosure, we will be clear about what you need to tell us.

We won’t ask you about your health before making a job offer unless that is necessary and we:

▪ Need to know about any reasonable adjustments that should be made to the recruitment process (that information is kept separate from the application form);

▪ Need to establish if you would be able to carry out an intrinsic part of the job;

▪ Need to check if you have a particular disability where that disability is an occupational requirement of the job;

▪ Are monitoring diversity (see below);

▪ Want to take positive action in respect of disabled people; or

▪ Have to ask health or disability-related questions because of a legal requirement.

As part of our equal opportunities monitoring, we may ask you to answer questions about yourself, including about your race, physical or mental health, and sexual orientation. This is for monitoring purposes only and to help us to identify any inequalities in our organisation. It is personal information, so we handle it very carefully and we store it separately from application forms. It is not taken into consideration when we are deciding whether to take an application forward in the recruitment process. That includes when we are deciding whether to offer you the job, and the terms of any offer.

You do not have to give us all or any of the information we collect for equal opportunities monitoring. Whether an applicant does or does not complete a monitoring form has no bearing whatsoever on our recruitment decisions.

Shortlisting

Our processes are fair and must be seen to be fair. If a member of staff involved in the recruitment process has a conflict of interest, they should immediately tell a member of HR A conflict of interest could include a relationship or friendship with a job applicant.

Shortlisting criteria will be role dependant but will be fair, consistent and in line with the Company Policy

Shortlisting will be carried out by the Recruiting Manager with advice and guidance from the HR team where necessary

We treat all applications confidentially and assess each by applying a pre-agreed scoring system that is based on the job specification and the person specification.

We will contact the successful and unsuccessful applicants as soon as possible after making our decision about who to take forward to interview, however we are not always able to inform unsuccessful candidates during the busy season or at peak times.

If we do not identify a suitable candidate, we may decide to re-advertise the vacancy or a different version of the vacancy.

Making a job offer

Once initial contact has been made, we will write to the successful candidate with an offer. That offer will include details of the terms and conditions of employment. We will explain how to accept our offer, including the timescale for that response.

A job offer will usually be made subject to certain conditions. These include one or more satisfactory references (where applicable), proof of professional qualifications, and confirmation of the right to work in the UK. We may also decide to make an offer conditional on a satisfactory medical examination and/or the results of any other specific checks that it is reasonable, necessary and proportionate for us to carry out.

Starting in a new job

We aim to introduce you to your new role as smoothly as possible. Our HR team and your direct line manager you all the necessary information and guidance for that to happen.

You will have to complete a probationary period. It’s important to note that this s not only for the company to make sure that we are happy for the employment to continue but also for you as the employee

Data protection

During the recruitment process we will need to collect, handle and store various data about you. This is likely to come from different sources including:

● Your application and covering letter;

● Your CV;

● Notes of your interview;

● Employer references (if required);

● Results of any undertaken pre-employment checks.

We will only collect data that is relevant to the recruitment decisions we need to make. We will only take up references (depending on the level of employment undertaken) on you with your consent, and if that consent is not provided the offer will be withdrawn.

Relevant data will be held confidentially, stored securely and retained for only as long as necessary, in line with our Data Protection and GDPR Policy.

Only information that has a bearing on the employment relationship will be transferred to your personnel file.

Re-deployment

Shorefield Holidays Limited will carefully consider the re-employment of applicants who have previously worked for the organisation. The HR Manager / Board of Directors must approve any re-employment of exemployees before an offer of employment is made. Leaving forms will be a vital source of information to the HR Manager and Directors; therefore, it is essential that the form be completed with total accuracy.

Enforcing this policy

If you are an employee of ours and believe that you have been discriminated against in breach of this policy, you should speak with your manager OR the HR Manager

You may want to take the formal step of raising a grievance, in which case you should follow our Grievance Policy. It is important to note that only an existing employee can raise a grievance under the policy, all other complaints will be dealt with under the external complaints procedure/policy

If you make a complaint under this policy in bad faith (where, for example, you know the allegation you are making is not true), we may regard that as a disciplinary issue. In serious situations, that could lead to dismissal without notice or payment in lieu of notice.

If you are found to have breached this policy by unlawfully discriminating against someone during the recruitment process, we may consider that to be misconduct. We might deal with it by providing (additional) training, issuing a warning or, in serious cases, considering dismissal using the disciplinary process

Recruitment Procedure

A flow chart of the Recruitment Procedure has been created to help simplify the process and make things clearer. You can ask HR for assistance at any point of this process – Please remember to send all interview notes from all candidates to HR once an offer has been accepted as this will close the process

Flow Chart Process

Vacancy Identified

Submit Employee Requisition form to HR

Role Advertised

Telephone Interviews carried out

Face to Face Interviews carried out

Successful Candidate –

Submit the following forms to HR:

• Interview Notes

• Application Form

• Employee ‘Make an Offer’ form

Job Offer to Candidate

Any rejections to be made on indeed ASAP

Vacancy Identified

Once a manager has identified that they have a vacancy in the department, possibly because of a member of their team leaving that they wish to replace or because they need an extra member of the team, the department manager completes an Employee Requisition Form (found on the HR Hub under Recruitment). This must be completed fully and passed to HR. If it’s a new role (rather than just replacing a leaving member of the team), the manager will need to get their senior manager and the Financial Director to sign the form before it comes to HR.

This form ensures HR have all the information required to be able to advertise the role, and can discuss with the manager where anything seems incorrect or unusual.

Role Advertised

HR will advertise the role using from the information on the Employee Requisition Form. By default this will go onto Indeed.co.uk, plus any other locations agreed. HR will confirm within a timescale agreed with the manager when this has been advertised, along with the associated costs.

Interviews

All applicant C.V.’s will go directly to the recruiting manager. There’s a separate detailed guide within the HR Hub for managing these on Indeed. Managers must insure any active vacancies are managed at least once a day to ensure the company remains a responsive employer.

Potential candidates must be contacted within 3 working days of their application.

The manager will go through the process of shortlisting, phone chats, interviewing and sending regret communications to unsuccessful applicants.

A Personal Details Form must be completed by every applicant who comes to Interview. Take account of any reasonable adjustments they request on this for the interview.

Interview notes must be completed for every person interviewed and passed to HR no later than when HR are asked to make an offer. Again a template for the interview can be found on the HR Hub.

PLEASEREMEMBERTHATALLCANDIDATESCANREQUESTACOPYOFTHEINTERVIEWNOTESSOPLEASEENSURE YOUASKTHESAMEQUESTIONSTOEACHCANDIDATE TOENSUREFAIRNESSANDEQUALITYINOUR PROCEDURE.

Please ensure you are not asking any discriminating questions or making any discriminating comments (Refer to the Company Discrimination, Equality and Inclusion policy on the HR Hub).

Before a manager interviews for the first time for the Company, a member of HR will assist and will sign them off as competent when both parties are happy.

When the recruiting manager has identified their preferred applicant they should submit their Interview Notes, Employment Application Form and Employee Make an Offer form to HR. An offer will only be made if these are fully completed.

Job Offer

HR will offer the role to the applicant and agree a start date for their Company Induction and will communicate this to the recruiting manager.

Alternatively, HR will authorise the recruiting manager to make the offer (this won’t be given without HR having the Interview Template, Employment Application Form and Employee Make an Offer form). The new employee must have a Department Induction on their first day and must not work before this. Potential dates for the induction to be carried out will be agreed between HR and the recruiting manager initially, and then with the successful applicant.

HR will promptly inform the relevant departments of start dates of new starters as relevant for the arrangement of training e.g. ICT, Reservations, Accounts.

The recruiting manager should prepare training for the new starter and engage the new starter during the period between job offer and start date. The content and frequency of this will depend upon the role and amount of time before they start with us.

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References Policy

This Policy sets out Shorefield Holidays Limited’s approach to providing and requesting employment references. Its purpose is to ensure that all references are accurate, fair, and consistent, and that they comply with relevant legal and regulatory requirements.

The policy applies to all employees involved in giving or requesting references on behalf of the Company. It aims to protect both Shorefield Holidays and its current or former employees by establishing clear procedures for managing reference requests and the information disclosed. By following this policy, the Company seeks to maintain integrity in its employment practices, safeguard confidential information, and support transparency and professionalism in all reference communications.

Legal Context and Responsibilities

There are several legal considerations involved in the provision and receipt of employment references. Under the Data Protection Act 2018, employees or former employees are not entitled to view references written on their behalf when the request for disclosure is made to the author. However, they may still have the right to request access to a copy of the reference from its recipient.

Those within the company who provide references owe a legal duty of care both to the individual concerned and to the recipient of the reference. This means that any reference must be true, accurate, and fair to the best of the referee’s knowledge and belief, and must not give a misleading overall impression. Failure to meet these standards may expose both Shorefield Holidays Limited and the individual providing the reference to legal action. Claims could include negligence or alleged discrimination, such as victimisation on the grounds of sex, race, or other protected characteristics. Similarly, a reference recipient could bring a claim for negligence if they suffer financial loss or damage as a result of an inaccurate or misleading reference.

To mitigate these risks and ensure consistency, all reference requests must be directed to the HR Team HR is responsible for preparing and issuing references on behalf of the Company.

Under no circumstances should any other employee or manager provide a reference written or verbal on behalf of the Company.

Procedure

Receipt of Requests

All requests for employment references must be directed immediately to the HR Team. Employees and managers must not respond directly to any reference requests, whether written, verbal, or informal (e.g., via telephone or email).

Verification of Authority

Upon receiving a request, HR will verify the identity and legitimacy of the requester to ensure the reference is being sought for a lawful and appropriate purpose.

Preparation of Reference

HR will prepare the reference using the Company’s approved format. References include factual information only, such as dates of employment and job title Any further additional information regarding performance, conduct, or reason for leaving will only be included where it is factually verifiable and relevant.

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Record-Keeping

A copy of each reference and the associated request will be retained securely on file in accordance with data protection and record retention policies.

Personal References

Employees may provide personal references in a private capacity if they wish. However, such references must make clear that they are given in a personal capacity only and not on behalf of Shorefield Holidays Limited. The Company’s name, logo, or letterhead must not be used in any personal reference.

Verbal References

Verbal references may only be given by authorised HR personnel and must be consistent with the content of any written reference. Notes of any verbal reference given must be documented and stored as part of the reference record.

Confidentiality and Data Protection

All reference information will be handled confidentially and in compliance with the Data Protection Act 2018 and the Company’s Data Protection Policy.

No information will be disclosed beyond what is necessary and lawful.

Security Policy

Shorefield Holidays Ltd recognise that a well-informed security policy is essential for protecting our organisation, employees and guests from various threats. Our security policy acts as a guideline for protecting our assets, while CCTV systems provide visual surveillance, and cybersecurity addresses the risks associated with cyberattacks

This policy is a comprehensive policy designed to address physical security (including CCTV), cyber security, and data privacy, whilst outlining procedures and responsibilities for all involved. It has been designed to ensure compliance with relevant data protection laws and standards while providing clear and current guidelines.

Shorefield Holiday Limited Security Policy outlines the procedures and responsibilities for maintaining the security of our premises, IT systems, and data. This applies to all employees, contractors, and visitors and guests who access any of the Shorefield Holidays Ltd sites or ICT Facilities.

CCTV Operation

Purpose: CCTV is used for security, crime prevention, evidence gathering and employee/guest safety.

Location and Signage: where CCTV cameras are installed in public areas, they will be clearly marked with signage indicating monitoring. Back office areas are monitored without sound for the above mentioned purpose – these may not be marked but this policy is a record of communication.

Data Retention: CCTV footage will be retained for specific retention period of 30 days in most areas and then securely deleted. Where a law enforcement agency is investigating a crime, images may need to be retained for a longer period Access & Disclosure: Disclosure of images to other third parties will only be made in accordance with the purposes for which the system is used and will be limited to:

• the police and other law enforcement agencies, where the images recorded could assist in the prevention or detection of a crime or the identification and prosecution of an offender or the identification of a victim or witness

• prosecution agencies, such as the Crown Prosecution Service

• relevant legal representatives

• line managers involved with Company disciplinary processes

• individuals whose images have been recorded and retained (unless disclosure would prejudice the prevention or detection of crime or the apprehension or prosecution of offenders).

The Chief Technical Officer (or another Director acting in their absence) is the only person who is permitted to authorise disclosure of information to external third parties such as law enforcement agencies. All requests for disclosure and access to images will be documented, including the date of the disclosure, to whom the images have been provided and the reasons why they are required. If disclosure is denied, the reason will be recorded.

Covert Recording:

The Company will only undertake covert recording with the written authorisation of the Financial Director and Chief Technical Officer (or another Directors acting in their absence) where there is good cause to suspect that criminal activity or equivalent malpractice is taking, or is about to take place and informing the individuals concerned that the recording is taking place would seriously prejudice its prevention or detection. Covert monitoring may include both video and audio recording. Covert monitoring will only take place for a minimal amount of time, consistent with the objective of assisting in the prevention and detection of suspected criminal activity or equivalent malpractice. Once the specific investigation has been completed, covert monitoring will cease. Information obtained through covert monitoring will only be used for the prevention or detection of criminal activity or equivalent malpractice. All other

information collected during covert monitoring will be deleted or destroyed unless it reveals information which the Company cannot be expected to ignore.

Covert photography, videoing or audio recording by employees, which has not been authorised by the Financial Director AND Chief Technical Officer (or other Directors acting in their absence) is deemed as gross misconduct (see Co. handbook).

Body Worn Cameras:

Body Worn Cameras are supplied to key Job Roles for the purpose of safeguarding employees that may be required to attend noise disturbance or incidences involving disruptive individuals.

The purpose of the BWC is to:

▪ Safeguard Employees

▪ Ensure independent and transparent incident recording

▪ Raise standards of service

▪ Reduce incident escalation

▪ Reduce complaints

Vehicle Tracking As Company assets, all vehicles owned by the company will be fitted with vehicle tracking devices. All employees required to drive a company vehicle are required to use a fob which is issued by the HR Department.

Data Protection: CCTV footage will be treated as personal data and processed in accordance with the Data Protection Act.

Physical Security Measures:

Security of the business is everyone’s responsibility

Access Control: All parks are private access to all parks is restricted to employees, guests and contractors and must be reported to Reception

Surveillance: All staff on park must wear the correct uniform and/or the identity badge with lanyard. All guests will be asked for identification and must produce this when asked by any member of staff. All contractors must report to Reception to be provided with a visitor pass to comply with this policy and identify them on park.

Emergency Procedures: security breaches, emergencies, and visitor access issues during working hours must be reported to the Duty Manger and outside of these hours to the site specific Park Wardens

Cyber Security

Acceptable Use Policy: this is an amalgamation of the separate policies issued by ICT including but not limited to: Agreement for Use of Equipment, Email Access Policy, Internet Access Policy and Treatment of Computer Viruses all of which can be found here K:\ADMINISTRATION\Company Forms\ICT\Shared Login Induction Policies Employees must adhere to all the policies listed under the acceptable use policy when using any Shorefield Holiday Ltd.’s IT system or accessing any company data.

Password Management

Strength and Complexity: Employees must create strong, unique passwords for all accounts.

Password Storage: We do not have the ability to store passwords but we do have an option to reset these within our systems if required

Data Classification and Access Control

Data Classification: Data will be classified according to its sensitivity, with appropriate access controls enforced.

Access Rights: Access to sensitive data will be limited to those who have a business need to access it.

Incident Reporting and Response: Employees must report any suspected security incidents or breaches immediately. Cybersecurity Training: Employees will receive regular cybersecurity training to raise awareness of threats and best practices.

Data Privacy

Compliance with Data Protection Laws: All processing of personal data will comply with the Data Protection Act.

Data Minimization: Only the necessary data will be collected and processed.

Purpose Limitation: Data will be processed for the specific purposes for which it was collected.

Data Subject Rights: Employees and visitors will have access to their personal data and the right to correct inaccuracies.

Roles and Responsibilities

Director and Chief Technical Officer: Andrew Bowden is responsible for the security of IT systems and data

All Employees: Employees are responsible for complying with this policy and reporting any suspected security breaches immediately by reporting to the correct department and/or manager

It is your responsibility as an employee to be diligent with the following:

• question and query visitors and/or guests when you have reason to

• check contractors/outside personnel have the correct authority to remove the Company's equipment.

• never discuss confidential information over the radios e.g., cash collection time

• always keep your passwords/security codes secret

• never leave a department unattended

• ensure equipment is locked or immobilised when idle

• keep all work keys in a safe place

If you become aware of any irregularities that may affect the Company's security, you must discuss these with a senior member of Management.

Policy Communication and Enforcement

Communication: This policy will be communicated via Shorefield People policy acceptance and must be acknowledged as part of the induction and any updates to this policy must be re-acknowledged by the same process

Enforcement: Non-compliance with this policy may result in disciplinary action, up to and including termination of employment.

Policy Updates

This policy will be reviewed regularly, as needed to reflect changes in Shorefield Holiday Ltd business and relevant regulations.

Sexual Harassment Policy

Shorefield Holidays Limited is committed to providing a safe environment for all its employees free from discrimination on any ground and from harassment at work including sexual harassment.

The company operates a zero tolerance policy for any form of sexual harassment in the workplace, treat all incidents seriously and promptly investigate all allegations of sexual harassment.

Any person found to have sexually harassed another will face disciplinary action, up to and including dismissal from employment.

All complaints of sexual harassment will be taken seriously and treated with respect and in confidence.

No one will be victimised for making such a complaint.

Definition of Sexual Harassment

Sexual harassment is unwelcome conduct of a sexual nature which makes a person feel offended, humiliated and/or intimidated. It includes situations where a person is asked to engage in sexual activity as a condition of that person’s employment, as well as situations which create an environment which is hostile, intimidating or humiliating for the recipient.

Sexual harassment can involve one or more incidents and actions constituting harassment may be physical, verbal and non-verbal. Examples of conduct or behaviour which constitute sexual harassment include, but are not limited to:

Physical conduct

▪ Unwelcome physical contact examples are; patting, pinching, stroking, kissing, hugging, fondling

▪ any form of inappropriate touching

▪ Physical violence, including sexual assault

▪ Physical contact, e.g. touching, pinching, tapping

▪ The use of job-related threats or rewards to solicit sexual favours

Verbal conduct

▪ Comments on a worker’s appearance, age, private life, etc.

▪ Sexual comments, stories and jokes

▪ Sexual advances

▪ Repeated and unwanted social invitations for dates or physical intimacy

▪ Insults based on the sex of the worker

▪ Sending sexually explicit messages by any means

Non-verbal conduct

▪ Display of sexually explicit or suggestive material

▪ Sexually-suggestive gestures

▪ Whistling

▪ Leering/staring suggestively

It is important to note that these examples are not exhaustive and that sexual harassment can include any conduct of a sexual nature which is unwanted and unwelcome by the recipient

Anyone can be a victim of sexual harassment, regardless of their sex and of the sex of the harasser. Shorefield Holidays Limited recognises that sexual harassment may also occur between people of the same sex. What matters is that the sexual conduct is unwanted and unwelcome by the person against whom the conduct is directed.

Shorefield Holidays Limited recognises that sexual harassment is a manifestation of power relationships and often occurs within unequal relationships in the workplace, for example between manager or supervisor and employee. Anyone, including employees of the company, customers, casual workers, contractors or visitors who sexually harasses another person will be reprimanded in accordance with this internal policy.

All sexual harassment is prohibited whether it takes place within Shorefield Holiday Limited sites or outside, including at social events, business trips or training sessions

Complaints Procedure

Anyone who is subject to sexual harassment should, if possible, inform the alleged harasser that the conduct is unwanted and unwelcome.

Shorefield Holidays Limited recognises that sexual harassment may occur in unequal relationships (i.e. between a supervisor and their employee) and that it may not be possible for the victim to inform the alleged harasser.

If a victim cannot directly approach an alleged harasser, they can approach This person could be another supervisor, a member of the human resources department, etc.

When HR receives a complaint of sexual harassment, they will:

▪ immediately record the dates, times and facts of the incident(s)

▪ ascertain the views of the victim as to what outcome they want

▪ ensure that the victim understands the company’s procedures for dealing with the complaint

▪ discuss and agree the next steps: either informal or formal complaint, on the understanding that choosing to resolve the matter informally does not preclude the victim from pursuing a formal complaint if they are not satisfied with the outcome

▪ keep a confidential record of all discussions

▪ respect the choice of the victim

▪ ensure that the victim knows that they can lodge the complaint outside of the company through the relevant legal framework e.g. Police etc

Shorefield Holidays Limited recognises that because sexual harassment often occurs in unequal relationships within the workplace, victims often feel that they cannot come forward. The company understands the need to support victims in making complaints and will provide the necessary means to do so including having someone available to accompany them throughout the process and/or support from one of our designated Mental Health First Aiders.

Informal complaints

If the victim wishes to deal with the matter informally, a member of the HR Team will:

▪ give an opportunity to the alleged harasser to respond to the complaint

▪ ensure that the alleged harasser understands the complaints mechanism

▪ facilitate discussion between both parties to achieve an informal resolution which is acceptable to the complainant, or refer the matter to a designated mediator within the company to resolve the matter

▪ ensure that a confidential record is kept of what happens

▪ follow up after the outcome of the complaints mechanism to ensure that the behaviour has stopped

▪ ensure that the above is done speedily and within 5 working days (where operationally possible) of the complaint being made

Formal complaints

If the victim wants to make a formal complaint or if the informal complaints procedure has not led to a satisfactory outcome for the victim, the formal procedure should be used to resolve the matter.

The report will be received by the Human Resources Team to instigate a formal investigation. A member of HR will:

▪ interview the victim and the alleged harasser separately

▪ interview other relevant third parties separately

▪ decide whether or not the incident(s) of sexual harassment took place

▪ produce a report detailing the investigations, findings and any recommendations

▪ if the harassment took place, decide what the appropriate remedy for the victim is, in consultation with the victim (i.e.- an apology, a change to working arrangements, a promotion if the victim was demoted as a result of the harassment, training for the harasser, discipline, suspension, dismissal)

▪ follow up to ensure that the recommendations are implemented, that the behaviour has stopped and that the victim is satisfied with the outcome

▪ if it cannot determine that the harassment took place, he/she may still make recommendations to ensure proper functioning of the workplace

▪ keep a record of all actions taken  ensure that the all records concerning the matter are kept confidential

▪ ensure that the process is done as quickly as possible and in any event within 10 working days (where operationally possible) of the complaint being made

Sanctions and Disciplinary Outcomes

Anyone who has been found to have sexually harassed another person under the terms of this policy is liable to any of the following sanctions:

▪ verbal or written warning

▪ transfer

▪ demotion

▪ suspension

▪ dismissal

The nature of the sanctions will depend on the gravity and extent of the harassment. Suitable deterrent sanctions will be applied to ensure that incidents of sexual harassment are not treated as trivial.

Certain serious cases, including physical violence, will result in the immediate dismissal of the harasser.

Support for anyone affected by sexual harassment

Help and support is available to anyone affected by sexual harassment.

▪ This includes:

▪ people who have experienced or witnessed sexual harassment

▪ managers dealing with sexual harassment complaints

▪ anyone accused of sexual harassment

Th support available at work is through Medicash after 1 months service

Outside sources of support include:

▪ Galop – LGBT+ sexual violence support

▪ Rape Crisis England and Wales

▪ Rape Crisis Scotland

▪ The Survivors Trust

▪ SurvivorsUK – for men and non-binary people affected by rape and sexual abuse

▪ Victim Support – in England and Wales

Sickness & Absence Policy

Shorefield Holidays Limited recognise sickness absence can be disruptive, costly and cause low morale, but can sometimes be inevitable. It is the policy of the Company to monitor, control and reduce frequent sickness absence, and to give appropriate support to employees who experience long-term sickness and/or disability and to minimise disruption in the workplace.

The Company is committed to adopting a consistent and fair approach to the management of sickness absence. This will be achieved by following procedures and taking actions to support employees through periods of ill health.

The term ‘Absence’ is used to cover ALL instances (authorised and unauthorised) when employees are not at work. All unauthorised absences will be monitored, investigated and sanctioned where necessary.

The Company will consider cases of absence for other reasons than sickness individually.

This Policy applies to all employees of the Company.

Absence Reporting

If you are unwell and unable to attend work, you must follow The company Absence Reporting procedure

Failure to report to work

If you fail to report to work, your Head of Department or a member of HR will contact you to ascertain the reason for your absence

If any representative of the Company is unable to contact you, we will write to you to establish the cause of your absence and the reason(s) for your lack of communication.

After every effort has been made to contact you, if the Company representative has still received no adequate communication from you, the Company may decide to terminate your employment for breach of contract.

Monitoring & Controlling Absence

Every person falls ill at some time during their working life. However, at a certain level, sickness absence becomes unacceptable because of its impact on your work colleagues and the business. If your sickness absence record reaches an unacceptable level, you will be informed of the Company’s concerns and the steps that will be taken to resolve those concerns.

The HR Team monitor absence on an on-going basis, considering absence frequency / patterns, duration and reasons for absences (using the Bradford Factor Indicator). Comparison with other employees and departments may also be made to ensure that a consistent standard is being adopted throughout the Company.

The management of sickness absence is conducted in accordance with Shorefield Holiday Limited’s Absence Management Procedure, which sets out the processes for managing absence due to sickness and ill health.

This procedure is closely aligned with the Disciplinary Procedure, ensuring a fair and consistent approach to managing attendance and addressing cases where absence levels cause concern or fail to meet company standards. Further details of the specific steps, responsibilities, and thresholds involved can be found in the Absence Management Procedure.

The absence record of new employees will be closely monitored during their probationary period and may be considered in deciding whether to continue the employment relationship.

Absence Trigger Points

This policy sets out the approach that will be used to manage sickness absence in the company, using a ‘trigger’ system.

Shorefield Holidays Ltd aims to support all employees who struggle due to illness or injury. However, the successful operation of the company does depend on employees attending for work and action will be taken to address unacceptable absence levels.

Shorefield Holidays Ltd operates a trigger system alongside the Bradford Factor scorning calculation for absence. This means that any employee who is absent for more than 3 occasions in a 3-month period will be required to attend an absence meeting. This is in conjunction with the Bradford Factor which will trigger when the score exceeds 50, whichever is first.

The Bradford Factor calculation: S x S x D = BF Score

▪ S = The no. of occasions absent in the last 52 weeks

▪ D = The total no. of days absent in the last 52 weeks

If an employee has a disability which affects their attendance, the situation will be reviewed to determine whether those specifically related periods of absence are to be included or revised in the trigger system.

Absence Counselling

If your absence record is causing concern, following your return-to-work interview, you will be asked to attend a confidential absence counselling meeting with your Head of Department. A member of the HR Team may also be present at the meeting. During this meeting, your absence(s) and the reasons for them will be discussed. You will be encouraged to discuss any medical, personal or work-related problems that may be causing you to be absent from work.

The Company may be able to offer you support and help you to resolve these problems. If appropriate, you may be encouraged to seek medical advice, if you have not already done so.

Following the absence counselling meeting, you will be advised in writing of the improvement in your attendance that is expected, the timescale for the improvement and the consequences of failure to improve your attendance. A copy of this letter will be placed in your personal documents on Shorefield People.

The Company may seek your consent to obtain a report from your doctor after or during any absence to clarify the nature of your illness and to indicate when or whether you are fit to return to or continue to work. We will require you to complete a Medical Report Consent Form, for us to obtain a medical report from your doctor. You are not obliged to give your consent, but it is advisable to do so to enable the Company to have sufficient information to reach a decision on how to manage your absence fairly and appropriately.

If, after appropriate counselling, review and / or medical investigation, your attendance does not improve, a decision may be taken to deal with your absence(s) formally through the Company’s Capability Procedure, which will involve formal absence warnings being given and may ultimately lead to the termination of your employment. You will always be advised of the improvement that is required, and the period of review at each stage of this formal procedure. The Capability Procedure may be adopted irrespective of the existence of appropriate medical or self-certificates covering absence. If the Company is of the view that you are malingering or an inadequate explanation for the absence is given, this may be treated as a misconduct issue under the Company’s Disciplinary Procedure.

Long Term Absence

If you have been off work for a long period of time or are suffering from a long-term illness (4 weeks or more), you and the Company and your Union Representative (if applicable) will identify an appropriate level of investigation including medical reports being obtained, support and absence counselling with you. If you wish to be accompanied to the meeting by a work colleague, please inform your Head of Department.

At all times, you will be fully consulted and kept advised of any developments and will also be made aware of the consequences of your absence continuing.

However, if your condition is unlikely to improve and, having carefully considered all reasonable options, you are unable to return to work, a decision may be taken to terminate your employment.

Disability

If you are suffering from any disability or have had a disability in the past which is likely to recur, which may affect your ability to perform your job properly or safely, then you must notify the Company immediately so that the Company can carry out a risk assessment and / or seek a medical opinion. You may also need to complete a further Company Health Questionnaire to update our records. If necessary, and if it is practicable to do so, the Company will make reasonable adjustments to your duties or working arrangements to allow you to return to work and / or minimise your level of absence in the future.

Sick Pay Entitlement

– please refer to the Employee Benefits Guide

Sickness

The Company reserves the right to withhold Company sick pay if you do not follow the correct procedure or fail to provide medical certificates. Company sick pay is not a right. The Company reserves the right to withhold it if the employee is persistently absent. The Company will consider an employee’s history of absence when deciding whether to pay Company Sick Pay. The employee’s history over several years may also be considered.

If you believe that the Company has breached this Policy / Procedure in any way, you should raise a grievance under the Company’s Grievance Procedure.

If any period of sickness is immediately before or after a period of holiday, then the Company reserves the right to treat the full period of absence as part of the holiday entitlement. This includes any weekend days between the sickness period and the holiday period.

Employees who fall ill during a period of holiday will have the right to take that leave at another time (subject to normal holiday booking procedure), provided that a Doctor’s Certificate/Statement of Fitness for Work Certificate is provided to cover that period.

In the case of an Employee who is absent owing to illness on the anniversary of the starting date (or close to) of their continuous employment, that Employee shall not be eligible for paid sick leave in respect of the following year until he/she has resumed his/her duties; the period from the anniversary of the starting date of their period of continuous employment until the return to duty being deemed to be part of the preceding year for the purpose of calculating eligibility. Any period of sickness continuing into a following year will not attract Company sick pay in that new year.

You are not eligible to paid sick leave during your notice period or if you are absent from work because of injuries arising from sporting activities or from dangerous hobbies or pastimes, other than Statutory Sick Pay.

Any member of staff who has another job or business interest shall not automatically be eligible for Company Sick Pay, only Statutory Sick Pay should this be applicable.

While paid sick leave will normally be granted this is always at the discretion of the HR Manager/Financial Director.

Permanent members of staff within their first year of employment, Casual and Seasonal staff have no eligibility to Company Sick Pay.

Jury Service

If you are called for jury service, you should present the “Jury Services Notification Slip” to your Head of Department or HR. However, you may be expected to return to work on such days as adjournments make this practicable, after discussion with HR. If the timing of the jury service conflicts with your work needs, you must inform HR in the first instance. You are entitled to claim statutory compensation from the Courts in respect of your jury service and the unpaid period of your absence, except if you are over state pensionable age. However, you may be entitled to expenses only.

This Policy does not form part of your terms and conditions of employment.

Absence Procedure

The purpose of this procedure is to ensure that all employee absences due to sickness or ill health are reported, recorded, and managed consistently and fairly across Shorefield Holidays Limited

Effective absence reporting enables the company to provide appropriate support to employees, maintain operational efficiency, and meet its legal obligations under UK employment and health and safety legislation.

Employees are expected to notify their line manager as soon as possible when they are unable to attend work due to sickness or injury. Timely and accurate reporting allows the business and department to manage workloads, arrange cover where necessary, and maintain up-to-date absence records.

This procedure outlines:

▪ The steps employees must follow when reporting sickness absence;

▪ The roles and responsibilities of employees, managers, and HR in the reporting process;

▪ The requirements for self-certification and medical certification (Fit Notes); and

▪ The process for recording, monitoring, and managing sickness absence.

By following this procedure, both employees and managers can work together to ensure that sickness absence is handled with sensitivity, transparency, and in accordance with the company’s Sickness & Absence Policy.

Employee Responsibilities

To ensure consistency and compliance with the company’s Absence Management Procedure, employees must follow these steps when reporting sickness absence:

1. Notification of Absence

Employees must notify their line manager or designated contact as soon as possible, ideally before their scheduled start time. Notification should include:

▪ The reason for absence (brief description of illness or injury)

▪ The expected duration of the absence

▪ Any urgent work or handover arrangements if applicable

2. Method of Notification

Employees should report their absence via telephone call to their line manager or in their absence, a member of the Senior Leadership Team/HR team Text messages, calls by another person/family members or social media notifications are not acceptable and may result in disciplinary action being taken

3. Self-Certification

For absences of up to 7 calendar days, employees may self-certificate providing the reasons for absence Notification must happen each day of the absence to keep your manager and the business informed of the situation

4. Medical Certification (Fit Note)

For absences of more than 7 calendar days, employees must provide a Fit Note (or doctor’s certificate) from a registered medical practitioner. Fit Notes should be submitted as soon as possible, ideally on the first day of absence beyond 7 days.

Employees are expected to cooperate with any reasonable requests for medical evidence or occupational health assessment if absence is prolonged or frequent.

5. Regular Communication During Long-Term Absence

For absences exceeding four weeks, employees should maintain regular contact with their line manager or HR to provide updates on their recovery and expected return-to-work date. Any adjustments to work duties or phased returns should be discussed and documented.

6. Return to Work

On returning to work, employees must attend a return-to-work discussion with their line manager to:

▪ Confirm the reason and duration of the absence

▪ Identify any support or adjustments required

▪ Update absence records accurately

7. Record Keeping

All absence notifications, self-certifications, and medical certificates will be recorded on Shorefield People and in compliance with data protection regulations. Accurate records help monitor trends, identify potential issues, and ensure fairness in managing attendance.

Manager Responsibilities

Managers play a crucial role in ensuring sickness absence is handled fairly, consistently, and in line with company policy. Their responsibilities include:

Recording Absences

Accurately record all employee absences in the company’s absence management system. Ensure that self-certifications and medical certificates are collected and filed.

Maintaining Communication

Maintain regular contact with employees during long-term absence to provide support and obtain updates on expected return-to-work dates. Offer guidance on company support mechanisms, such as occupational health, if appropriate.

Return-to-Work Discussions

Conduct a return-to-work meeting after each period of sickness absence to:

▪ Discuss the reason for absence and any ongoing health concerns

▪ Agree on any adjustments or support needed for a smooth reintegration

▪ Record the discussion accurately in the employee’s absence record

Monitoring Patterns of Absence

Monitor frequency, duration, and patterns of absence (short-term, long-term, intermittent) and identify early warning signs of potential issues, such as repeated short-term absence or stress-related sickness.

Escalation and Support

Refer cases to HR when absence levels exceed acceptable thresholds or when medical advice or occupational health input is required. Ensure compliance with company policy and employment legislation when addressing prolonged or frequent absences.

Triggers for Formal Review

Formal absence reviews may be triggered when:

▪ An employee reaches the company’s absence trigger threshold of 3 periods in 3 months or Bradford Factor Score of 50+

▪ There are patterns of absence that suggest a workplace issue, health concern, or potential misconduct.

▪ Long-term sickness absence requires adjustments, phased return, or consideration of fitness for work

During a formal review, the manager and HR will:

▪ Examine the employee’s absence record

▪ Discuss any underlying causes or medical concerns

▪ Agree on actions, which may include support measures, referrals to occupational health, or further monitoring

Link to Disciplinary Procedure

▪ Where absence is unauthorised, persistent, or unexplained, or if there is evidence of misuse of sickness reporting, the case may be handled under the company’s Disciplinary Procedure.

▪ The Absence Management Procedure is aligned with the Disciplinary Procedure to ensure a fair and transparent approach.

▪ Any action taken will be proportionate, documented, and in line with employment law and company policy.

Support and Wellbeing

Shorefield Holidays Limited recognises that sickness absence can result from personal health issues or workplace factors. Support available includes:

▪ Flexible work arrangements or reasonable adjustments for employees with ongoing health needs

▪ Employee wellbeing programme (Medicash) which included counselling, or mental health support through our team of mental Health First Aiders

This framework ensures that the Absence Reporting Procedure is clear, fair, and legally compliant, covering the responsibilities of both employees and managers, triggers for review, and links to disciplinary processes.

Absence Management Procedure

Shorefield Holidays Limited recognise sickness absence can be disruptive, costly and cause low morale, but can sometimes be inevitable. It is the policy of the Company to monitor, control and reduce frequent sickness and absence, and to give appropriate support to employees who experience long-term sickness and/or disability and to minimise disruption in the workplace.

The Company is committed to adopting a consistent and fair approach to the management of sickness absence. This will be achieved by following the below procedure and taking action to support employees through periods of ill health or long term absences.

What is Absence?

The term ‘Absence’ is used to cover ALL instances (authorised and unauthorised) when employees are not at work. All unauthorised absences will be monitored, investigated and sanctioned where necessary.

The Company will consider cases of absence for other reasons than sickness individually.

What is Sickness Absence?

Sickness absence is defined as a period during which an employee is unable to attend work or carry out their normal contractual duties due to physical or mental ill health Sickness absence may be:

▪ Short-term – usually absences of up to four weeks, generally self-certified by the employee; or

▪ Long-term – continuous absences of four weeks or more, supported by a Fit Note (medical certificate) issued by a registered medical practitioner.

Sickness absence does not include other forms of authorised leave (such as annual leave, parental leave, or compassionate leave) or unauthorised absence. Absence Management Procedure following trigger breach OR Bradford Factor score of 50+

1. The employee will be informed in writing that they are required to attend a disciplinary meeting for absence. They will be informed that they are entitled to be accompanied at the meeting by a colleague or a trade union representative. A copy of the employee’s absence record is to be attached to the letter sent.

2. At the disciplinary meeting, the manager will ask the employee if the employee agrees with the absence record. If there are any areas of disagreement, the employee will be asked to detail these, and the meeting will be adjourned whilst the records are checked. If the company has made an error, the employee will be informed, and the matter will go no further. If the company’s records are correct, the meeting will be reconvened.

3. The employee will be asked to explain their absence. The employee will be asked if there are any special circumstances that need to be considered. The manager will adjourn to consider whether a warning will be issued.

4. Unless there are exceptional circumstances, a disciplinary warning will be given when the employee has reached the trigger point or their Bradford Factor has exceeded 50

5. If the employee already has a live disciplinary warning relating to attendance, the next level of warning will be given. The levels of warning are written warning, final written warning and dismissal

If the employee has any questions or concerns they should contact the HR department.

Right to appeal a decision

An employee has the right to appeal the warning. Appeals must be submitted within 5 working days of being notified of a decision. This should be done in writing and clearly state the reasons for their appeal. The decision made at appeal is final.

For further information or assistance please contact the HR department

This procedure does not form part of the employment contract, and can be amended at any time.

Smoking & Vaping Policy

The Directors of Shorefield Holidays Limited recognise that smoking and vaping are personal choices. While we respect each individual’s right to choose whether to smoke or vape, this must be balanced against our responsibility to protect others from the risks associated with second-hand smoke and vape fumes.

This policy is not intended to stop people from smoking or vaping entirely, but to ensure it is done only in designated areas and during permitted break times, in a way that does not impact the health, safety, or comfort of others.

The Policy

Shorefield Holidays Limited is committed to ensuring the health, safety, and wellbeing of all employees, contractors, and visitors by maintaining a smoke-free and vape-free working environment. To achieve this smoking and vaping are strictly prohibited in all enclosed and shared spaces, including offices, corridors, restrooms, meeting rooms, and Company vehicles.

Smoking and vaping are only permitted in designated outdoor smoking areas, which are clearly marked and located away from entrances and windows.

Employee Responsibility

Employees who choose to smoke or vape are expected to:

▪ Only smoke or vape in designated smoking areas provided by the Company.

▪ Use their allocated lunch or rest breaks if they wish to smoke or vape not during working time.

▪ Ensure that smoke or vapour does not enter buildings or enclosed workspaces, such as by standing well away from doors, windows, and ventilation intakes.

▪ Dispose of cigarette ends, vape pods, and related waste safely and responsibly in the bins provided.

▪ Be mindful of timekeeping and return to work promptly after breaks.

▪ Respect colleagues and visitors by following this policy at all times and setting a positive example.

Manager Responsibility

Managers and supervisors play a key role in ensuring this policy is applied consistently and fairly. They are expected to:

▪ Communicate the No Smoking & Vaping Policy to all team members, contractors, and visitors.

▪ Lead by example by following the policy themselves at all times.

▪ Monitor compliance within their areas of responsibility, including ensuring employees only smoke or vape in designated areas and during allocated break times.

▪ Address breaches of this policy promptly and fairly, following the Company’s disciplinary procedures where necessary.

▪ Support employees who wish to stop smoking or vaping, including signposting them to available support or cessation services.

▪ Ensure designated smoking areas are well maintained, safe, and clearly signposted. By fulfilling these responsibilities, managers help create and maintain a healthy, safe, and respectful working environment for everyone

Contravention of this Policy

All employees, contractors, and visitors are expected to comply fully with this No Smoking & Vaping Policy.

▪ Any breach of this policy such as smoking or vaping in non-designated areas, during working

time, or in Company vehicles will be treated seriously and inline with the Company’s disciplinary procedure

▪ Managers will address non-compliance promptly, reminding individuals of the policy and expected standards of behaviour

▪ Repeated or serious breaches may result in formal disciplinary action in line with the Company’s disciplinary procedure, which could include written warnings or further sanctions.

Contractors or visitors who fail to comply may be asked to leave the premises. Consistent enforcement of this policy is essential to maintain a safe, healthy, and legally compliant workplace for everyone

Policy Review

This No Smoking & Vaping Policy will be reviewed regularly to ensure it remains effective, relevant, and compliant with current legislation and best practice.

▪ The policy will be formally reviewed if there are changes in legal requirements or Company operations.

▪ Employee feedback and incident reports may be considered as part of the review process.

▪ Any updates or amendments to the policy will be communicated promptly to all employees and contractors

Regular review ensures this policy continues to protect health, promote safety, and support a positive working environment for everyone

Social Media Policy

Shorefield Holiday Limited want to encourage our colleagues to share their passion for their work through social media in a reasonable and appropriate way that does not put either the business, customers or colleagues at risk.

Social Media Definition

Social media is an interactive online media that allows users to communicate instantly with each other or to share data in a public forum. It includes social and business networking websites such as Facebook, Twitter, LinkedIn, & Instagram. Social media also covers video and image sharing websites such as YouTube and Flickr, as well as personal blogs. This is a constantly changing area with new websites being launched on a regular basis. Therefore, this list is not exhaustive.

This policy applies in relation to any social media that employees may use.

Use of Social Media at Work Employees are not permitted to access social media websites or to keep a blog using the Company’s IT systems and equipment at any time. This includes laptops and handheld computers, or devices distributed by the Company for work purposes. The Company has added most of the websites of this type to its list of restricted websites.

Most of us will use social media in our personal lives and increasingly in our professional lives too. Social media is a fantastic tool for connecting with our customers, members and colleagues to share our great work as well as telling people about we have to offer. It is not to be used at any time in a detrimental way to the business or employees within the business

Where employees have their own computers or devices such as laptops and handheld devices they must limit their use of social media on this equipment to outside their normal working hours (for example during lunch breaks). However, employees may be asked to contribute to the Company’s own social media activities during normal working hours, for example, by writing Company blogs or newsfeeds, managing a Facebook account or running an official Twitter or LinkedIn account for the Company.

Employees must always be aware that, while contributing to the Company’s social media activities, they are representing the Company. Company’s Social Media Activities where employees are authorised to contribute to the Company’s own social media activities as part of their work, for example for marketing, promotional and recruitment purposes, they must adhere to the following rules:

▪ Use the same safeguards as they would with any other type of communication about the Company that is in the public domain

▪ Any communication that could be seen to be detrimental or discriminatory to either the company or its employees will be dealt with under the Company’s disciplinary policy and a potential outcome could be dismissal.

▪ Ensure that any communication has a purpose and a benefit for the Company

▪ Obtain permission from their line manager before embarking on a public campaign using social media

▪ Request their line manager to check and approve content before it is published online

▪ Follow any additional guidelines given by the Company from time to time

Stop and Search Policy

Shorefield Holidays Ltd must ensure that the security of the site is maintained, therefore safety and security are of primary importance. To help maintain the safety and security of the staff and guests, the company reserves the right under this policy to exercise a stop and search of its employees.

The purpose of this policy is to outline:

▪ why the organisation believes that it is necessary to enforce the right of stop and search

▪ how employees will be chosen to be stopped and searched;

▪ the manner in which searches will be carried out

▪ where searches will take place

Right to stop and search

In accordance with this policy, the organisation reserves the right to stop and search all employees, carry out a search of personal belongings and vehicles on the organisation's property and carry out a search of all workplace areas, including lockers and any company vehicles.

Employees will be asked to consent to a search and will be required to complete a stop and search authorisation form (which can be found on the HR Hub under General Policies/security)

Reasons for searches

Shorefield Holiday Ltd reserves the right to undertake searches of employees within its premises. This is to protect both the organisation and its staff from illegal activities such as:

▪ any theft of the organisation's property or property belonging to another

▪ the possession or supply of illegal substances.

Employees are advised that a search on an employee does not indicate that they are under any suspicion of wrongdoing and searches will be carried out at random. However, the organisation also reserves the right to stop and search an employee when it reasonably suspects that they have committed an illegal act.

Shorefield Holidays Ltd reserve the right, after obtaining a signed Employee Authorisation Form, to conduct personal searches of an employee or an employee’s property and/or vehicle

Personal Search Process

At the outset of a personal stop and search, the search operative will outline the following to the person being searched.

▪ The reason for the search - setting out the grounds of suspicion, in line with the Company policies and procedures.

▪ Confirm that a written record will be made of the search.

▪ Confirm that the search will not be of an intimate nature.

▪ Ask if they wish a colleague be present during the search.

▪ Ask the employee being searched if they wish for the search to be carried out by a manager of the same gender (if genders are different).

▪ Confirm that the search will be of desk, drawers, bags, lockers, exterior clothing or pockets of coats, jeans, etc.

The Company will usually require the person who owns the property to be present when it is searched. An HR manager may, exceptionally, authorise a search to take place in their absence if the suspicion is substantiated by supporting evidence such as CCTV etc

Vehicle Search Process

Shorefield Holidays Ltd may conduct a search of vehicles as they enter or leave the park premises. At the outset of a vehicle stop and search, the manager will outline the following to the employee whose vehicle is being searched.

▪ The reason for the search - setting out the grounds of suspicion, in line with the Company policies and procedures.

▪ The driver will be asked to move the vehicle into the search bay to avoid obstructions and will be asked to turn off the engine and leave the vehicle.

▪ Confirm that a written record will be made of the search.

▪ Ask if a colleague should be present during the search.

Shorefield Holidays Ltd will usually require the person who owns the vehicle to be present when it is searched. An HR manager may, exceptionally, authorise a search to take place in their absence if the suspicion is substantiated by supporting evidence such as CCTV etc

Bag/coat Search Process

The Company may conduct a search of bags/coats as the owner enters or leaves the Organisation premises. At the outset of a bag/coat search, the searching manger will outline the following to the person whose bag/coat is being searched.

▪ The reason for the search (setting out the grounds of suspicion, in line with Organisation rules, policies and procedures, etc).

▪ The person who owns the bag/coat will be directed to a private room for the search to be conducted.

▪ The person who owns the bag/coat will be asked to empty some or all of the bag/coat contents, or alternatively pass the bag/coat to the search operative for a search to be undertaken.

The Company will usually require the person who owns the bag or coat to be present when it is searched. An HR manager may, exceptionally, authorise a search to take place in their absence if the suspicion is substantiated by supporting evidence such as CCTV etc.

Policy Updates

This policy will be reviewed regularly, as needed to reflect changes in Shorefield Holiday Ltd business and relevant regulations.

This policy will be reviewed annually or as needed to ensure its effectiveness and relevance.

Sustainability & Environmental Policy

Shorefield Holidays Limited recognises that it has a responsibility to the environment beyond legal and regulatory requirements. We are committed to reducing our environmental impact and continually improving our sustainability performance as an integral part of our business strategy and operating methods.

Our Commitment

▪ Protect and enhance the environment wherever possible.

▪ Support climate change targets and contribute to a sustainable future.

▪ Integrate environmental considerations into all business decisions.

▪ Encourage our guests, employees, and partners to act responsibly.

Climate & Health Connection

Shorefield Holidays Limited acknowledge that climate change has significant negative effects on health, including air pollution, the spread of disease, extreme weather events, food insecurity, and pressures on mental health. By addressing our environmental footprint, we aim to reduce these impacts and contribute to healthier communities

Wellness & Workforce

We believe that a healthy workforce underpins a strong and effective green policy. We therefore:

▪ Promote wellness initiatives to support the physical and mental health of employees.

▪ Encourage active and sustainable lifestyles.

▪ Recognise the link between staff wellbeing and our environmental goals

Objectives

To deliver on our commitments, Shorefield Holidays Limited will:

1. Reduce waste and increase recycling across our operations.

2. Minimise energy and water consumption.

3. Invest in renewable and sustainable energy sources where practical.

4. Promote biodiversity across our parks and natural spaces.

5. Encourage guests to make sustainable choices during their stay.

6. Monitor, measure, and review our environmental performance annually

Continuous Improvement

This policy will be regularly reviewed to ensure it remains relevant, effective, and aligned with both environmental best practices and our business objectives

Travel Expenses & Subsistence Policy

Shorefield Holidays Limited understands that some travel is required between parks outside of our normal duties, hours or where we are usually based. Our policy sets out clear rules, guidelines, and procedures for employees who incur expenses while traveling for business purposes.

Overview

This policy ensures that travel arrangements, accommodation, and daily allowances are managed efficiently, fairly, and in compliance with applicable financial regulations. It is designed to provide clarity and consistency, helping employees understand what is reimbursable and the processes for claiming expenses.

Legitimate Business Expenses

Use of a private vehicle for Business Travel

▪ Mileage Payments

Employees who are required to use their own car for company business will be reimbursed at a fixed rate of 45p per mile travelled. Where more than one employee is travelling to the same destination, they are expected to share transport wherever practicable. In such cases, an additional 5p per mile per car will be paid to the driver.

▪ Authorisation and Claims

All mileage claims must be submitted using the company’s official expense claim form on Yooz and authorised by the relevant Head of Department. Mileage from home to the employee’s normal place of work is not reimbursable and must be deducted from any claim.

Use of a personal vehicle for long-distance journeys must receive prior approval from the Head of Department or a Director before the trip takes place.

▪ Insurance

Employees are responsible for ensuring that their personal vehicle is insured for business use. Evidence of appropriate insurance may be requested by the Company at any time. (Refer to the Safe Driving Policy and Manual for further guidance.)

▪ VAT Receipts and Documentation

Valid VAT fuel receipts must accompany all mileage expense claims. This allows the Company to recover the VAT element on reimbursed mileage.

- For specific business trips, the fuel receipt must correspond to that journey and be dated before the travel took place.

- For employees who use their car regularly and claim monthly, all fuel receipts for the relevant period must be attached.

Failure to provide appropriate receipts may result in the claim being rejected or delayed.

Accommodation

and Incidental Expenses

▪ Authorisation and Booking

All accommodation must be approved in advance by a Director. Employees should book standard rooms only. Room upgrades are permitted only if offered at no additional cost to the Company.

Where possible, employees should make payment via the Accounts/Finance Department or in situations where this is not possible, arrange for the accommodation bill to be sent directly to the Company by contacting the Accounts/Finance Department in advance.

If the employee is required to pay personally (using a credit or debit card), a detailed, itemised bill must be obtained and attached to the expense claim form, along with the relevant VAT receipt. All bills should be carefully checked for accuracy before signing.

▪ Personal Incidental Expenses

The Company will reimburse personal incidental expenses incurred during overnight stays (e.g., telephone calls, laundry, or similar minor items) up to a maximum of £5.00 per night within the UK.

- Receipts must be provided for all incidental expenses.

- The Company will only reimburse actual expenses incurred, not a flat rate of £5.00 per night.

- The limit applies to the entire trip, meaning that a five-night stay would have a total allowance of £25.00 for incidental expenses.

For overseas travel, the maximum allowance is £10.00 per night under the same conditions.

Meals and Drinks

Reimbursement is permitted for the cost of meals and non-alcoholic beverages consumed while away from the normal place of work.

▪ Evening Meals

When staying overnight on company business, employees may claim the cost of an evening meal up to a maximum of £30 per person, which includes soft drinks only. Any alcoholic beverages must be paid for personally by the employee.

- Itemised receipts must be submitted with the expense claim.

- If the total exceeds the £30 limit, the employee will be invoiced for the excess amount.

▪ Lunch Allowance

A lunch-time snack may be claimed up to a maximum of £10 when travelling on company business. Receipts are required for all claims.

▪ Day Travel and Refreshments

Employees who are required to work away from their normal place of work (excluding other Shorefield parks) for example, attending a training course or external meeting are entitled to reimbursement for light refreshments and soft drinks up to a maximum of £10.

Exceeding Allowances

Any meal or refreshment claims that exceed the stated limits will be the responsibility of the employee, and the Company reserves the right to recover these costs directly.

Other Expenses

Necessary incidental costs related to business travel may be claimed, such as laundry (for extended stays), business-related phone calls, internet access, or printing of work-related documents. All such claims must be

supported by valid receipts. All expenses must be authorised in advance by the Directors or a Senior Manager and any unauthorised expenditure will not be reimbursed.

You must follow the Company procedures for claiming expenses and all claims must state the reason for the expenditure and the names of employees that it was for. All of this information is to be provided on the Yooz Form – more details on this and the training needed can be provided by the Accounts and Finance Department

Eligibility and Conditions

Temporary Workplaces: Travel is only claimable if it's to a temporary workplace, not the employees regular home or main office.

Work-Related: Expenses must be for official business and directly related to the duties of your employment.

Review and Monitoring

This policy will be reviewed on a regular basis to ensure it meets the needs of all members and reflects current best practices.

Uniform Policy

Overview

Here at Shorefield, our standards are high, and we expect the same from you. Our customers judge the standard of our parks not only by the grounds as they see them but also our team, so it is important that you always look smart and professional.

If you work in an area where a specific uniform is required, we will provide this to you along with a name badge and lanyard, both of which must be worn whenever you are at work. It is your responsibility to make sure all uniform is looked after and cared for.

Uniform allocation will be done within your first month, to ensure we are representing Shorefield. Each department will have guidelines regarding the uniform and what is expected so please make sure you have received this from your manager

Table of uniform allocation by department

If you require additional uniform due to health conditions, please speak to HR. When you collect new uniform, you must return old uniform to HR.

Managers & Office Staff

If you are an employee in a management role or officed based role, you are required to dress in a smart/casual manner. This is to ensure that you are dressed appropriately for the workplace. Acceptable attire would be as follows:

• Bottoms: Smart trousers, tailored shorts, chinos, jeans (no distressed features) and skirts (appropriate length) are acceptable. No gym wear, track suit bottoms or shorts in the office working environment.

• Tops: Shirts, polo shirts, blouses, dresses, and jumpers are acceptable. Hoodies are not accepted.

• Shoes: Should be suitable for the environment you are working in. Health and safety must be followed, so please be mindful of the suitability of footwear. Trainers of neutral colours and sandals are acceptable but must be suitable for a working environment.

• ID lanyards: Should be worn when moving around the park, this helps the public identify you as an employee.

Working within our Head office, you must remember that you are representing the company, and should be upholding our company standards.

The following is classed as unacceptable attire for all employees:

• frayed or torn jeans, trousers, shorts and skirts

• hot pants, excessively short shorts or skirts

• sports or yoga clothing, for example tracksuits and football shirts

• low cut, revealing, cropped, mid-drift or transparent tops

• tops with slogans or symbols that could cause offence

• flip flops

• Patterned tights or leggings

• dirty clothing, or clothing in a poor state of repair

Appearance

• Your appearance should be clean and smart, reflecting the high standards of our company.

• It is your responsibility to look after your uniform and to keep it clean and tidy

• Your items will be replaced when they wear out, through normal wear and tear. Items will be replaced once you hand the old items back.

Footwear

• Safety shoes will be issued if you work in an area which requires them and must be worn.

• For other areas you should wear appropriate shoes, or boots.

Make up

• Make-up should not be excessive.

• In fresh food preparation areas, for health and safety reasons, no nail varnish, false nails, or nail jewellery may be worn, this also includes gel nails. You may wear nail varnish in other areas but this must be well maintained.

• Strong perfumes or aftershaves should not be used

Hair

• Your hair should be tied back if it is longer than shoulder length and must be neat and tidy

• Facial hair should be neat, tidy and groomed. If you work in a food preparation area, beard nets must be worn.

Jewellery

• All jewellery is worn at your own risk as it can be dangerous when you are lifting and carrying. It may be in your best interest to leave it safely at home, however, if you choose to wear it, it should be kept to a minimum an tucked into your uniform where possible

• Rings can be worn in moderation.

• Earrings are ok to wear if they are safe and practical.

• A small nose stud may be worn (except if you work in a food preparation area).

Tattoos

• Tattoos are ok in the workplace, but any tattoos likely to cause offense must not be visible and you should try and cover it with your uniform.

ID Badge and Lanyard

• Your name badge should always be worn when on park, This helps people identify you.

Religious Dress

• Sensitivity and flexibility will be shown, and every effort made to accommodate the wearing of religious dress.

• Where safety standards cannot be complied with due to religious or cultural reasons, we will look for employment in another department where these requirements can be met.

Employees

who are required to wear protective clothing and equipment

The Personal Protective Equipment (PPE) at Work Regulations 1992 and the 2022 amendments place a duty on employers to ensure that suitable PPE is provided to employees where risks to health and safety cannot be adequately controlled by other means.

Employees have a responsibility to take reasonable care of the PPE provided to them and report any issues to their Manager or HR

Employees who occupy roles that require protective clothing or personal protective equipment under the PPE at work regulations such as hard hats, gloves and masks, are required to wear this clothing whilst at work, whether working on the Company’s premises or elsewhere on Company business, whenever required by law.

Any personal protective equipment will be supplied and maintained by the Company and it remains the property of the Company.

In the event that you fail to return your personal protective equipment supplied to you by the Company in good condition or at the end of your employment, or you lose or damage your personal protective equipment during employment, the replacement cost of your personal protective equipment may be deducted from your final salary payment, or from your next salary payment. This deduction provision forms part of your contract of employment.

If your job brings you into contact with machinery or involves working with food, for health and safety and/or hygiene reasons your hair must be kept short or tied back at all times (and covered if working with food) and you must not wear jewellery.

Exceptions to this policy

Finally, the Company accepts that members of certain ethnic or religious groups are subject to strict religious or cultural requirements, or may have particular religious or cultural preferences, in terms of their clothing and appearance. The Company recognises the diversity of religions and cultures of its employees and will take a sensitive approach when this affects dress and uniform requirements.

If you are uncertain as to whether a particular item of clothing is acceptable or not, please speak to the HR department.

Policy compliance

If you fail to comply with the Uniform Policy, this is a serious matter and will be dealt with in accordance with the Company’s disciplinary procedure.

In addition, depending on the circumstances of the case, you may be required to go home and change your clothing. If this happens, you have no right to be paid for the period of your absence from work.

Wellbeing Policy

Shorefield Holidays Limited is committed to ensuring wellbeing in the workplace and strives to promote and support the physical, mental, and emotional wellbeing of all employees. The company recognises that wellbeing at work is essential for positive engagement, productivity, and overall employee satisfaction. The company aims to create a supportive work environment where employees feel valued, safe, and motivated.

Principles

• Everyone has the right to a safe, healthy, and supportive environment.

• Wellbeing includes mental, emotional, social, and physical health.

• The company values work-life balance and encourages practices that support personal and professional wellbeing.

Employee Responsibility

All employees of Shorefield Holidays Limited have a responsibility to engage with the wellbeing initiatives offered to ensure their own wellbeing is being looked after and supported appropriately with the tools the company has to offer. Its is also expected that the employee will respect the wellbeing of others and report any concerns related to workplace wellbeing or company culture

Work-life Balance

All employees are legally entitled to request flexible working from day one of their employment (Refer to the Flexible Working Policy for information) Shorefield Holidays Limited will address all requests sympathetically and in line with the company Flexible working policy and procedure

Requests to work from home will be given careful consideration. A request will only be allowed if it will not have a negative impact on the smooth operation of the company. Employees must consider that some jobs can never be successfully carried out from home and that this may be an impossibility due to the nature of the role performed.

Employees who are allowed to work from home will be expected to attend the workplace at least once per week. This will allow effective communication and ensure that the employee does not feel isolated from the work team.

Employees who work part time will be encouraged to attend team briefings. To achieve this, the timing of team briefings will vary to cover the different working patterns of employees.

Providing Medical Assistance to Employees and Promoting Healthy Options

To promote the health of all employees Shorefield Holidays Limited will do the following;

• Provide health cash plans for employees who are grades 8 to grade 1.

• Provide access to a confidential counselling service. This service is not run by Shorefield Holidays Limited and no personal information is given to the company

Providing access to Financial Wellbeing Assistance to Employees

To promote financial wellbeing to all employees, Shorefield Holidays Limited will do the following;

• Provide access to regular financial presentations

• Provide the opportunity to have 1 2 1 financial health checks through our partner of choice (HSBC)

• Provide access to a confidential counselling service. This service is not run by Shorefield Holidays Limited and no personal information is given to the company

Encouraging Employee Fitness

To promote exercise and fitness Shorefield Holidays Limited will do the following;

• Provide Fitness Club membership, level is dependent on grade. Employees must abide by the terms and conditions of the membership agreement.

• From time to time, events will be arranged for employees to participate in fitness activities. Employees wishing to arrange an event should contact the HR Department.

Promoting Dignity at Work

Shorefield Holidays Limited believes that all employees should be able to work without fear of being harassed or distressed by their colleagues, customers or other contacts in the workplace. Any employee who is distressed by events at work and believes that their dignity has been violated or they have suffered harassment should talk to their line manager. This will be addressed in confidence. If it is not appropriate to speak to the line manager employees should speak to a member of the HR team.

The company will act promptly to investigate any allegations of unacceptable behaviour in the workplace and take into consideration any breach of company policy taking the appropriate action in accordance with that policy

Shorefield Holiday Limited will support employees in getting over any distress that has been caused. Employees who harass colleagues, or engage in otherwise upsetting behaviour, could be subject to disciplinary action.

Minimising the Stressful Impacts of Work

All jobs can have times when the work is particularly busy, or particularly demanding. Shorefield Holidays Limited recognises this and will support employees where reasonably possible

If it does not form part of your role e.g. out of hours call outs etc, employees are not expected to be answering emails from home in the evenings. If employees find that they are regularly needing to work from home in the evenings they must discuss this with their line manager and work together with the support from the HR Team to find resolution.

If employees are struggling to cope with the demands of their job they should discuss this with their line manager or a member of the HR Team and where possible, consider any reasonable adjustments which could be put into place

Managing Sickness Absence Effectively

Employees who are absent due to sickness must adhere to the Company Sickness Absence Procedure. Employees should not return to work if medical advice is that they are not fit to work.

Should a phased return to work programme following a long period of sickness absence be required, this must be agreed between the employee and their line manager with support from the HR Team.

Whilst an employee is on long term sick leave their line manager or a member of the HR Team will keep in touch on prior agreed dates/times. The purpose of these meetings/conversations are to ensure that key communications are received by the employee and to ensure that the employee still feels part of the work team. This should be agreed early on in the absence and a return to work should be kept in mind.

Confidentiality

All information shared in relation to wellbeing support will be handled confidentially and with respect.

Review and Monitoring

This policy will be reviewed on a regular basis to ensure it meets the needs of all members and reflects current best practices.

Whistleblowing Policy

Policy Aims

This policy is designed to:

• Protect whistleblowers from detrimental treatment so that concerns can be raised without fear.

• Support the values of Shorefield Holidays Limited.

• Provide a confidential, fair, and transparent process for addressing employee concerns about malpractice within our business

Applicability

This policy applies where employees make disclosures in good faith, and in their reasonable belief, such disclosure tends to show that one or more of the following is being, or is likely to be, committed:

• A criminal offence.

• A failure to comply with legal or regulatory obligations.

• A miscarriage of justice.

• Endangering the health or safety of an individual or individuals.

• Damage to the environment.

• Deliberate concealment of any of the above.

• Financial malpractice, impropriety, or fraud.

This policy does not apply to malicious or knowingly false reports. Any employee making such a report may be subject to Shorefield Holidays Limited’s disciplinary procedures.

Principles

When the company receive a disclosure of this kind, we will:

• Ensure that no employee raising concerns in good faith and with reasonable belief will suffer retribution, even if the concerns are later found to be mistaken.

• Respect the anonymity of the reporting individual unless they consent to disclosure.

• Handle all concerns fairly, consistently, and justly.

Procedure

If an employee reasonably believes, in good faith, that one of the matters listed above exists or is likely to occur, they should:

• Report the concern to their senior manager, who will inform the Compliance Officer, Paula Curtis. If the employee is reluctant to approach their senior manager, they may report directly to the Compliance Officer.

• The Compliance Officer will enter the report into the Company’s Whistleblowing Register and notify the relevant authorities where appropriate.

• The reporting employee will be informed of the person handling the matter and provided with contact details for follow-up if required as well as receive feedback on the action taken. If the employee is dissatisfied with the outcome, they have the lawful right to raise the matter with the Financial Conduct Authority (FCA) or other appropriate external bodies.

The Law

This policy has been drafted in consideration of the Public Interest Disclosure Act 2018 (“the Act”), which protects employees from dismissal or penalty for raising serious concerns in the public interest.

The Act, reflected in the Employment Rights Act, provides employees with the right to bring a claim before an Employment Tribunal if they suffer retribution for whistleblowing.

Useful Contact Details

For confidential advice, contact Public Concern at Work (charity):

▪ Whistleblowing Advice Line: 020 7404 6609

▪ General enquiries: 020 3117 2520

▪ Financial Conduct Authority (FCA) Whistleblowing Helpline: 020 7066 9200

Email: whistle@fca.org.uk

Address: Intelligence Department (Ref PIDA), Financial Conduct Authority, 25 The North Colonnade, Canary Wharf, London E14 5HS Other Useful websites:

▪ www.direct.gov.uk

▪ www.fca.org.uk

▪ www.pcaw.co.uk

Workplace Mediation Policy

Shorefield Holiday Limited encourages mediation as a voluntary and confidential way to resolve workplace disputes early, in line with the ACAS Code of Practice on Discipline and Grievance Procedures (effective 6 April 2009). Mediation is intended to improve communication and relationships while avoiding escalation to formal procedures where possible.

What Mediation Is

Mediation is a flexible, voluntary process to help employees resolve:

▪ Personality clashes

▪ Differences of opinion

▪ Communication issues

▪ Workplace grievances

It cannot be used for:

▪ Disputes over contract terms

▪ Complaints about company policies

▪ Objections to the Company fulfilling legal obligations (e.g., health and safety compliance)

Confidentiality:

All discussions during mediation are confidential.

Role of the Mediator

A neutral third party either an internal senior staff member or an external accredited mediator will:

▪ Coordinate and facilitate meetings

▪ Encourage open and respectful communication

▪ Meet parties individually if needed

▪ Suggest ways to resolve the dispute (if appropriate)

The Company’s decision on the mediator is final, and all costs are covered by the Company.

Employee Responsibilities

Employees participating in mediation must:

▪ Approach the process positively

▪ Respect the views of others

▪ Act professionally at all times

Workplace Companions

▪ Generally, companions (colleagues or union reps) are not involved.

▪ Employees may request a companion for moral support however family, friends, or legal representatives are not permitted.

▪ Requests should be communicated when confirming the mediation date.

Formal Procedures

Mediation does not replace formal disciplinary or grievance procedures. The Company may implement formal processes where deemed appropriate.

Record

A note of the conversation may be placed on the employee’s record.

Manager/HR Guidance for Mediation

Before Mediation:

▪ Ensure the process is voluntary.

▪ Identify a suitable mediator.

▪ Confirm date, location, format, and whether a companion will attend.

During Mediation:

▪ Maintain strict confidentiality.

▪ Facilitate open discussion and respectful dialogue.

▪ Meet parties individually if needed.

After Mediation:

▪ Document key outcomes confidentially.

▪ Decide if formal disciplinary or grievance processes are necessary.

Dos and Don’ts:

▪ Do: Encourage participation, stay neutral, record key points.

▪ Don’t: Force attendance, involve family/legal representatives, disclose confidential details.