Policies and Procedures

Quality Policy

FeRFA, the Resin Flooring Association, represents the leading manufacturers, specialist contractors, raw material suppliers and specialist service providers involved in industrial and commercial resin flooring, screeding and surface preparation. FeRFA is the training provider for resin flooring, surface preparation and screeding.

Our headquarters are based in Stamford Lincolshire.

We value our members and strive to provide our members with services that meet and even exceed their expectations.

We are committed to continuous improvement that provides a framework for measuring and improving our performance.

We have the following systems and procedures in place to support us in our aim of total customer satisfaction and continuous improvement throughout our business:

• A variety of committees responsible for different activities
• A customer complaints procedure
• A selection process for members against set criteria
• Training and development for our members
• Measurable quality objectives which reflect our business aims
• Management review of customer feedback and complaints.

Our internal procedures are reviewed regularly. The policy review date is annually.

Risk Management

Definition of Risk Management

Risk is the chance or possibility of loss, damage, injury or failure to achieve objectives caused by an unwanted or uncertain action or event. Risk management is a planned and systematic approach to the identification, evaluation and control of those risks which can threaten the assets or financial and organisational well-being of FeRFA.

Policy Statement

FeRFA recognises that it has a responsibility to manage risks effectively in order to control its assets and liabilities, protect its employees and community against potential losses, minimise uncertainty in achieving its goals and objectives and maximise the opportunities to achieve its vision.

FeRFA is aware that some risks can never be eliminated fully and it has in place a strategy that provides a structured, systematic, and focused approach to managing risk.

Risk management is an integral part of FeRFA’s arrangements and has been built into the management processes as part of the overall framework to deliver continuous improvement.

Objectives

The objectives of FeRFA’s risk management strategy are to:-

• Raise awareness of the need for risk management;
• Minimise loss, disruption, damage and injury and reduce the cost of risk, thereby maximising resources;
• Inform policy and decision making by identifying risks and their likely impact.

These objectives will be achieved by:

• Establishing clear roles, responsibilities and reporting lines within FeRFA for risk management
• Effective communication with, and the active involvement of Board Members
• Monitoring arrangements on an on-going basis

Responsibility for Risk Management

FeRFA recognises that it is the responsibility of all employees to have regard for risk in carrying out their duties. If uncontrolled, risk can result in a drain on resources that could better be directed, and to the meeting of FeRFA’s objectives.

Employees have a duty to work safely, avoid unnecessary waste of resources and contribute to risk management initiatives in their own area of activities. The co-operation and commitment of all employees is required to ensure that Association resources are not squandered as a result of.

Social Value

FeRFA have a strong ethic regarding our team and the value they add to association and promote working together in diverse circumstances.  Work hard to achieve your objectives and deliver results and do the right thing.  FeRFA is transparent in its values of honesty, integrity, respect and expects trust and kindness, with respect to its employees, and members.

The creation of social, economic, and environmental wellbeing is embedded within our procedures, processes and in the way we work informing our decisions to maximise value. This policy outlines our commitment towards engagement to maximise, manage, and measure the social value we create on our projects.

Community engagement

We are committed to making a positive contribution throughout our collaboration with our members, and the wider community to foster mutually beneficial relationships.

Safe and diverse supply chains

We support local businesses by providing opportunities for small, medium, micro-sized businesses by procuring goods and services locally, while following our fair payment and procurement practices and recognition of modern slavery risks.

We encourage the use of local resources and labour, to reduce our impacts whilst upholding our principles of equality, inclusion, and diversity

Education

We collaboratively organise, deliver, and promote activities to inspire future generations into the industry to enable sustainable career development within our specialist industry.

Skills and employment

We support local people into employment by providing opportunities and apprenticeships to gain new skills that create meaningful employment opportunities and we will support schemes including work experience and apprentiships. Career progression upholds the principles of equality, inclusion, and diversity.

Environmental sustainability

We ensure the efficient use of resources to manage and reduce our impact on the environment, recognising the importance of net zero emissions.

Inclusion, mental health, and wellbeing

We measure the embedded social value we create through employment creating opportunities for the short and long term unemployed and the improved mental health created through community and charitable activities.

We will, and expect our supply chain to, create a culture of good work which will have a positive effect on our mental health, our society, and the economy

Review

This policy shall be reviewed on an annual basis.

Training

FeRFA recognises that investment in team development is key to the association’s success and future.  That is why we aim to train all of our employees to the highest standard. The association encourages everyone in its employment to participate in as wide a range of training as possible.  We consider Health and Safety training is mandatory in accordance with legislation and the company’s duty of care to provide a safe, healthy, working environments for all its employees.

The training needs of each individual are assessed with consideration for the following:

• Competency to carry out their duties
• Qualifications and experience
• Awareness of Health and Safety responsibilities
• Competency to use IT and electronic devices (work equipment).
• Competency to operate
• Competency to drive company vehicles
• Specialist equipment and Tools

All new employees will be given induction training and provided with the associations Health and Safety Policy and Employee Handbook.

FeRFA will ensure that specific training will be given to individuals to ensure we have sufficient numbers of qualified staff in the following:

• Health & Safety
• First Aider at Work
• Manual Handling
• Fire Safety

The association will provide training on all association IT systems and processes for the relevant individuals with a commitment to continuous investment and development of all.

Wellbeing

Scope

• Mental health problems and stress can affect anyone, regardless of their position in the organisation.  This policy applies equally to all employees.

• The implementation of this policy will also be supported by other health and safety policies as well as the Equal Opportunities, Alcohol and Drugs, Bullying and Harassment and Flexible Working policies.

Aim of the Policy

• To create and promote a culture where employees are able to talk openly about their job and mental health problems and to report difficulties without fear of discrimination or reprisal.

• To create and promote a workplace environment that supports and promotes the mental wellbeing of all employees.  We acknowledge that certain working conditions and practices can negatively affect employee’s mental wellbeing, including aspects of work organisation and management, and environmental and social conditions that have the potential for psychological as well as physical harm.

Objectives

• To tackle workplace factors that may negatively affect mental wellbeing, and to develop management skills to promote mental wellbeing and manage mental health problems effectively.

• Give employees information on and increase their awareness of mental wellbeing.

• Provide opportunities for employees to look after their mental wellbeing, for example through physical activity, stress-buster activities, and social events.

• Offer employees flexible working arrangements that promote their wellbeing.

• Ensure all employees have clearly defined job descriptions, objectives ad responsibilities and provide them with good management support, appropriate training and adequate resources to do their job.

• Manage conflict effectively and ensure the workplace is free from bullying, harassment, discrimination, and racism.

• Establish good two-way communication to ensure staff involvement, particularly during periods of organisational change.

• To develop a culture based on trust, support, and mutual respect within the workplace.

Policy Actions

• Give non-judgmental and proactive support to individual staff who experience mental health problems.

• Deal sympathetically with staff suffering from mental health problems due to circumstances outside the workplace, and who consequently find it difficult to do their jobs properly.

• Give new employees a comprehensive induction program providing an understanding of the organisation, the established policies and procedures, and the role they are expected to carry out.

• To provide support and assistance for employees experiencing mental health difficulties.

• Ensure individuals suffering from mental health problems are treated fairly and consistently and are not made to feel guilty about their problems.

• Encourage employees to consult their own GP, or a councillor of their choice.

• Investigate the contribution of working conditions and other organisational factors to mental ill health and remedy this where possible.

• In cases of long term sickness absence, put in place, where possible, a graduated return to work.  If we have cause to be concerned about your health (including how this may impact your long-term employment and /or performance), we may ask you to engage with an occupational health advisor of our choice to assess your fitness to carry out your role and /or seek advice on the impact of your health condition on your role. Should we seek further medical information, actions may be taken in line with recommendations provided.

• Make every effort to identify suitable alternative employment, in full discussion with the employee, where a return to the same job is not possible due to identified risks or other factors.

• Treat all matters relating to individual employees and their mental health problems in the strictest confidence and share on a “need to know” basis only with consent from the individual concerned.

• To positively encourage the employment of people who have experienced mental health problems by providing fair and non-discriminatory recruitment and selection process.

• Show a positive and enabling attitude to employees and job applicants with mental health issues.

• Provide adequate resources to enable managers to implement the organisations agreed workplace mental wellbeing policy and to raise awareness of issues through eLearning, team meetings, toolbox talks, information leaflets and notice board literature.

Recruitment and Selection

• As an employer we recognise that people who have or have had mental health problems may have experienced discrimination in recruitment and selection procedures.  This may discourage them from seeking employment. While some people will acknowledge their experience of mental health issues openly, others may fear that stigma will jeopardise their chances of getting a job.  Given appropriate support, the vast majority of people who have experienced mental health problems continue to work successfully, as do many with ongoing issues.

• We aim to ensure that all employees involved in recruitment and selection are briefed on mental health issues are aware of the Equality Act ad are trained in appropriate interview skills.

• We aim to make it clear, in any recruitment or occupational health check undertaken, that people who have experienced mental health issues will not be discriminated against and that disclosure of a mental health problem will enable both employee and employer to assess and provide the right level of support or adjustment.

• We do not make assumptions that a person with a mental health problem will be more vulnerable to workplace stress or take more time off than any other employee or job applicant.

Responsibilities

• Everyone has a responsibility to contribute to making the workplace mental wellbeing policy effective.
• Managers have a responsibility to:
• Monitor the workplace, identify hazards and risks, and take steps to eliminate or reduce these as far as is reasonably practicable.
• Ensure good communication between management and staff particularly where there are organisational and procedural changes.
• Assist and support employees who are known to have mental health problems or are experiencing stress outside work – for example due to bereavement or separation.
• Ensure staff are provided with the resources and training required to carry out their job.
• Monitor workloads to ensure that people are not overloaded.
• Monitor working hours and overtime to ensure that staff are not overworking and monitor holidays to ensure staff are taking their full entitlement.
• Ensure staff are provided with meaningful developmental opportunities.
• In addition, senior management will ensure that staff performing a management or supervisory function have sufficient competence to discharge that function in a manner consistent with the maintenance of mental health in the workplace.  This included providing training to managers how to recognise and deal with mental health issues and the methos of communicating the options available to the individual, including access to accredited mental health services.

Employees are encouraged to raise issues of concern and seek help and support from their line manager.

Review and Monitoring

• FeRFA will monitor how effectively the policy meets its aims and objectives.
• Indicators to measure effectiveness could include:
• Working hours and patterns.
• Accidents at work
• Staff complaints
• Staff sickness levels
• Staff turnover
• Use of occupational health or counselling services
• Early retirement through ill health
• Exit interviews.

The policy will be reviewed annually to ensure it remains relevant.

Cyber Protection

The risk of data theft, scams, and security breaches can have a detrimental impact on a company’s systems, technology infrastructure, and reputation. As a result, Professional Preparation Contractors UK Ltd (The Preparation Group) has created this policy to help outline the security measures put in place to ensure information remains secure and protected.

Purpose.

The purpose of this policy is to (a) protect FeRFA data and infrastructure, (b) outline the protocols and guidelines that govern cyber security measures, (c) define the rules for company and personal use, and (d) list the company’s disciplinary process for policy violations.

Scope.

This policy applies to all of FeRFA’s remote workers, permanent, and part-time employees, suppliers, and/or any individuals with access to the association’s electronic systems, information, software, and/or hardware.

Confidential Data.

FeRFA defines “confidential data” as:

• Unreleased and classified financial information.
• Member, supplier, and employee information.
• Patents, business processes, and/or new technologies.
• Employees’ passwords, assignments, and personal information.
• Association contracts and legal records.

Device Security:

Company Use.

To ensure the security of all company-issued devices and information, FeRFA employees are required to:

• Keep all association-issued devices password-protected (minimum of 8 characters). This includes tablets, computers, and mobile devices.
• Secure all relevant devices before leaving their desk.
• Obtain authorization from the CEO before removing devices from association premises.
• Regularly update devices with the latest security software.

Personal Use.

FeRFA recognizes that employees may be required to use personal devices to access association systems. In these cases, employees must report this information to the CEO for record-keeping purposes. To ensure association systems are protected, all employees are required to:

• Ensure all personal devices used to access company-related systems are password protected (minimum of 8 characters).
• Install full-featured antivirus software.
• Regularly upgrade antivirus software.
• Lock all devices if left unattended.
• Ensure all devices are protected at all times.
• Always use secure and private networks.

Email Security.

Protecting email systems is a high priority as emails can lead to data theft, scams, and carry malicious software like worms and bugs. Therefore FeRFA requires all employees to:

• Verify the legitimacy of each email, including the email address and sender name.
• Avoid opening suspicious emails, attachments, and clicking on links.
• Look for any significant grammatical errors.
• Avoid clickbait titles and links.
• Contact the IT partner regarding any suspicious emails.

Transferring Data.

FeRFA recognizes the security risks of transferring confidential data internally and/or externally. To minimize the chances of data theft, we instruct all employees to:

• Refrain from transferring classified information to employees and outside parties.
• Only transfer confidential data over FeRFA networks.
• Obtain the necessary authorisation from senior management.
• Verify the recipient of the information and ensure they have the appropriate security measures in place.
• Adhere to FeRFA data protection law and confidentiality agreement.
• Immediately alert the IT partner regarding any breaches, malicious software, and/or scams.

Disciplinary Action.

Violation of this policy can lead to disciplinary action, up to and including termination. FeRFA’s disciplinary protocols are based on the severity of the violation. Unintentional violations only warrant a verbal warning, frequent violations of the same nature can lead to a written warning, and intentional violations can lead to suspension and/or termination, depending on the case circumstances.

Preventing Facilitation of Tax Evasion

FeRFA’s policy is to have a zero tolerance to tax evasion and facilitation of tax evasion. This means we expect all our employees and anyone who works for us, not to engage in any activity which evades tax or facilitates or may facilitate the evasion of tax by any other person (company or individual). It does not matter whether the taxes are UK taxes or are due to an overseas fiscal authority. Nor will we engage with any third party (including those who contract with us or otherwise provide services to us) who do not have a similar policy. Specifically, we expect all employees and associated persons to be able to identify and take steps to prevent any scenarios where there may be a risk that they are facilitating others to commit tax evasion, either in the UK or overseas. We support the questioning and eventual declining of business where there are any suspicions of tax evasion or the facilitation of tax evasion. All cases of suspicion in relation to future or existing business should be first reported (see below) before making any decisions in relation to existing business relationships or committing the business to transact in the manner proposed. We expect all parties acting with us or for us to adopt a similarly robust approach.

Below are examples of risk areas and red flags that could arise during the course of your everyday working and which should raise a concern under this policy. Examples could include, but are not restricted to the following:

• A supplier, contractor or anyone in your role within our business asking you to do something that does not match up with official documentation – for example, paying into a different account than that which is specified on the invoice.
• You are feeling under pressure to process or approve an invoice (or make changes to our contractual terms) that you don’t feel makes sense, for example in terms of changing the payment details or VAT amount.
• You receive an invoice from a third party that appears to be non-standard or customised or is different to what you expected.
• Contras where invoices are not exchanged for the face value of services/good exchanged.
• You are aware of any short cuts in our Supplier or Customer Take On procedures (e.g. someone you know circumventing the supplier set-up and P2P process which means that there are no checks on the company/person they were purchased from or contract in place)
• Someone who works for a third-party supplier offering you what seems like a discount, e.g. because they tell you they don’t need to charge you VAT – without giving a reason
• Being concerned about the set up and/or supporting paperwork of a particular transaction that you think may not reflect the true commercial reality or fact pattern.
• Someone at work (for example an employee or a contractor) claiming to have found a ‘short cut’ in how much tax they pay or you are aware that tax is not being declared.
• Someone at work (for example an employee or a contractor) claiming illegitimate expenses o Someone asking for a favour that is not in line with your company policy.
• Any other knowledge or suspicion that anyone in our business, either in the UK or any other country, is evading or facilitating tax evasion.

YOUR RESPONSIBILITIES The prevention, detection and reporting of facilitation of tax evasion is the responsibility of all employees throughout the organisation. This means that you must have read, understand, and comply with all the information contained within this policy, and with any training or information relating to the Criminal Finances Act you receive. Any individual who breaches this policy may face disciplinary action potentially resulting in dismissal for misconduct or gross misconduct. Similarly, we may terminate our relationship with other individuals, organisations and other associated person working on our behalf if they breach this policy. What to do if you have a suspicion or concern? If at any time you have a reasonable belief, suspicion, or concern that, in any way connected to our business, someone has been engaged in facilitation of tax evasion or other wrongdoing (however insignificant it may be and whether it involves an employee of a third party) you must raise this with [your line manager or the compliance manager]. What to do if you are a party to facilitation of tax evasion? You must tell [your line manager or the compliance manager or senior management] as soon as possible if you are asked to do something (either by someone else in the business or a third party) where you suspect there may be facilitation of tax evasion or believe that you are a victim of another form of unlawful activity. What to do if you feel threatened or vulnerable? If you refuse to act on a request (either by someone else in the business or a third party) that you think may result in the facilitation of tax evasion, you may feel worried about potential consequences. We take this very seriously and will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken. ONGOING MONITORING, We will maintain an effective system for monitoring compliance procedure to ensure we remain committed to our zero tolerance to facilitation of tax evasion. This includes training (both face-to-face and online as appropriate) and forms part of the induction process for all new employees. All existing employees receive regular, relevant training on how to adhere to this policy. Our zero-tolerance approach to facilitation of tax evasion must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and as appropriate thereafter.

Equal Opportunities

FeRFA is committed to providing equal opportunities for all employees, including job applicants in line with the Equality Act 2010. https://www.gov.uk/guidance/equality-act-2010-guidance.

The Association provides equal opportunities regardless of disability, skin colour, race, religion, religious or philosophical beliefs, age, sex, pregnancy and maternity, marital status, sexual orientation, gender reassignment, ethnic origin, or national origin. Therefore, any employee or service provider found to be in breach of this equal opportunities policy, will be subject to disciplinary action in accordance with the disciplinary procedures.

Equality, diversity, and inclusion

FeRFA is committed to encouraging equality, diversity and inclusion among our workforce, and eliminating unlawful discrimination.

The aim is for the workforce, including service providers to be truly representative of all sections of society and our members, and for each individual to feel respected and able to give their best.

The association – in providing services – is also committed against unlawful discrimination of its members or the public.

The policy’s purpose is to:

• provide equality, fairness and respect for all in our employment, whether temporary, part-time or full-time or contracted services.

• not unlawfully discriminate because of the Equality Act 2010 protected characteristics of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality, and ethnic or national origin), religion or belief, sex, and sexual orientation.

• oppose and avoid all forms of unlawful discrimination. This includes in pay and benefits, terms and conditions of employment, dealing with grievances and discipline, dismissal, redundancy, leave for parents, requests for flexible working, and selection for employment, promotion, training or other developmental opportunities.

The association 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 and service providers are recognised and valued.

• This commitment includes training employees about their rights and responsibilities under the equality, diversity and inclusion policy.

• Responsibilities include staff conducting themselves to help the association provide equal opportunities in employment, and prevent bullying, harassment, victimisation, and unlawful discrimination.

• All staff and service providers, should understand they, as well as their employer, can be held liable for acts of bullying, harassment, victimisation and unlawful discrimination, in the course of their employment, against fellow employees, members, suppliers and the public
  
  
• Take seriously complaints of bullying, harassment, victimisation and unlawful discrimination by fellow employees, members, suppliers, visitors, the public and any others in the course of the associations work activities.
  
  Such acts will be dealt with as misconduct under the association’s grievance and/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 and service providers, 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 association.
  
  
• Decisions concerning staff being 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 association 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.

The equality, diversity and inclusion policy is fully supported by The Board of Directors.

Details of the organisation’s grievance and disciplinary policies and procedures are available on request.  

Use of the association’s grievance and/or disciplinary procedures does not affect any employee’s right to make a claim to an employment tribunal within three months of the alleged discrimination.

Anti-corruption and Bribery

Ferfa is committed to applying the highest standards of ethical conduct and integrity in its business activities.  Every individual acting on the Associations behalf is responsible for maintaining the Associations reputation and for conducting its activities honestly and professionally.

 The Association does not tolerate any form of bribery, whether direct or indirect, by, or of, its employees, officers, agents or consultants or any person or companies acting for it or on its behalf.  The Directors are committed to implementing and enforcing effective systems to prevent and eliminate bribery, in accordance with the Bribery Act 2010.

The Association has an anti-bribery and corruption policy, together with policies on gifts and corporate hospitality (“Policies”), outlining the Association’s position on preventing and prohibiting bribery and corruption.

A bribe is a financial advantage or other reward that is offered to, given to, or received by an individual or company (whether directly or indirectly) to induce or influence that individual or company to perform public or corporate functions or duties improperly.

Anyone acting for or on behalf of the Association is strictly prohibited from making, soliciting, or receiving any bribes or unauthorised payments.  As part of its anti-bribery measures the Association accepts transparent, proportionate, reasonable, and bona fide hospitality and promotional expenditure, whether given or received.

Individuals acting for the Association should note that bribery is a criminal offence that may result in up to 10 years imprisonment and/or an unlimited fine for the individual and an unlimited fine for the Association.

Individuals acting for the Association are encouraged to report any suspected bribery in accordance with the policies and procedures to The Board of Directors.

Conflict of Interests

Directors have a legal obligation to act only in the best interests of FeRFA. We recognise that Directors’ personal and professional connections can bring benefits to the work of FeRFA but they can also give rise to conflicts of interest, to which Directors must respond effectively. Directors must not knowingly put themselves in any position where their duties as a Director may conflict with any personal interest. The existence of a conflict does not however reflect on the integrity of the affected Director, provided it is properly addressed.

Definition: conflict of interest

A conflict of interest is any situation in which a Director’s personal interests or loyalties could, or could be seen to, prevent the Director from making a decision in the best interests of FeRFA. A conflict exists even where there is the possibility that a Director’s personal or wider interests could influence their decision-making. Even the perception of a conflict of interest can damage FeRFA and/or the Director’s reputation.

Definition: Director benefit

In accordance with accepted good practice, we define “Director benefit” as any instance where money, or other property, goods or services, which have a monetary value, are received by a Director from the company. The law states that Directors cannot receive a benefit from the company, whether directly or indirectly, unless they have an adequate legal authority to do so. The term “Director benefit” does not include any payments to reimburse legitimate out-of-pocket expenses.

Examples of benefits are where the Board of Directors decide to:

• sell, loan or lease FeRFA assets to an individual FeRFA Director;
• acquire, borrow or lease assets from an individual FeRFA Director for the Association;
• pay a Director for carrying out their Directorship;
• pay a Director for carrying out a separate paid position within the Association, even if that Director has recently resigned as a Director;
• pay a Director, or a person or company closely connected to a Director, for providing a service to FERFA;
• employ a Director’s spouse or other close relative at FERFA; or
• allow a Director, who is also a member, to influence FERFA membership provision for their personal advantage.

Disclosure of interests

Individual Directors who fail to identify and declare any conflicts of interest will fail to comply with their personal legal responsibility to manage conflicts of interest and act only in the best interest of the Association. Further, FERFA must be aware of Directors’ potential and actual conflicts of interest as soon as possible and therefore we maintain a register of interests, identifying and recording any relevant conflicts and associated parties. Directors are required to complete the declaration formon taking office, and to resubmit annually thereafter. A new declaration should be made when any new conflict of interest arises.

The interests of Directors, members of the same household, close family members, and close friends, partners, or business associates (i.e., those who may expect to influence or be influenced by that person in their dealings with FERFA) should be disclosed. The disclosure includes the nature of the relationship, employment details, other Directorships, charity trusteeships, companies where more than 20% of shares are held, ownership as a sole trader, or partnership in a business. Specifically:

• At each Board meeting, a standing agenda item will ask for updates on disclosures, with a particular view to further items on that agenda.

• The secretariat will maintain a register of interests, which will be made available to the Board of Directors, FERFA’s auditors, Companies House, or any other entity that has a legal right or requirement to inspect our records.

• The following information must be disclosed by every Director:

• Directorships and/or trusteeships of other companies, unincorporated organisations or other bodies. This includes Board membership, or equivalent, of voluntary or charitable organisations, public or government bodies, educational organisations, or any other similar governing body of which s/he is a member.

• Partnership in any business or other venture.

• Shareholdings or other financial [ownership] interests in, membership of, or employment by organisations which are likely to be FERFA competitors, customers, or suppliers.

• Any financial interest in or ownership of any property purchased, leased, used, or occupied by FERFA or its associated companies.

• Any loans of money or property made to FERFA or its associated companies.

• Any other dealings with FERFA or its associated companies by which s/he stands to gain financially or in some other manner.

• Any benefit which is received or available from FERFA or its associated companies, whether as a Director or otherwise.[1]

• Any other interest, activity or relationship which is, or might pose, a conflict of interest with FERFA or its associated companies, or which is, or might be, prejudicial to FERFA or its associated companies, or which does, or might, comprise s/he acting in a professional manner as an FERFA Director.

Directors are required to disclose interests of family members and close business associates in the same manner as above, specifying the names and relationships of the relevant individuals.

If any Director has an inextricable conflict of interest, s/he will draw to the Board’s attention the nature of the conflict, either ahead of or at the start of the relevant Board meeting. The Board shall determine whether the conflict is of such a nature that the Director should be asked to withdraw from the meeting for that item of business. Without limiting the Board’s discretion on deciding on such issues, as a general rule Directors will be asked to withdraw from a meeting if s/he is likely to derive, either directly or indirectly, any personal benefit or gain from the item being discussed.

Board decisions taken in accordance with this policy will be reported in the minutes of meetings.

Data Protection

The information provided in declarations of interest is processed in accordance with data protection principles of the Data Protection Act 2018 and the General Data Protection Regulation (2018). Data is processed only to ensure Directors act in the best interest of FERFA. The information provided is not used for any other purpose.

Non-compliance

The Board shall review any instances of non-compliance with this policy or any conflict of interest which may be deleterious to FERFA. It may, if appropriate, request the Director concerned to resign from the Board or to take such action as it thinks appropriate to protect the interests of FERFA and its associated companies.

[1] This does not include FERFA membership, formal remuneration package, legitimate travel and subsistence payments, or any indemnity insurance provided to protect individuals as FERFA Directors.

Corporate Criminal Policy

The purpose of this policy is to communicate The Associations approach to the Corporate Criminal Offence of the Failure to Prevent the Criminal Facilitation of Tax Evasion (“CCO”).

A criminal offence is committed under this legislation where an associated person of The Association (such as an employee, contractor or agent) deliberately and dishonestly facilitates a taxpayer evading tax, and FeRFA has not put in pace reasonable preventative procedures.

Key Principles

The Following basic principles are applied by FeRFA:

• Ensuring that we have reasonable prevention procedures in place to prevent any person associated with FeRFA from facilitating tax evasion. Our key procedures comprise:

• Obtaining assurances and warranties from suppliers that they have reasonable prevention procedure in place.

• Providing training to our staff and being clear about the consequences if a person associated with FeRFA facilitates tax evasion.

• Providing a pathway for reporting wrongdoing and providing protection for whistle-blowers.

• Operating existing and implementing new procedures which reduce the opportunity for employees to facilitate tax evasion, and regularly renewing these for effectiveness and improvement.

• Adopting a zero-tolerance attitude towards the criminal facilitation of tax evasion.

• Where internal investigations indicate a person associated with FeRFA has facilitated tax evasion, they will be reported to the authorities and FeRFA will fully support prosecution to the fullest extent of the law.

• Not to use the services of others who are unable to provide assurance that they have reasonable prevention procedures in place.

Who this policy applies to?

This policy applies to all persons associated with FeRFA including for all employees, contractors, agents, and any person acting on behalf of FeRFA.

Responsibilities

• All persons associated with FeRFA are responsible for adhering to this policy

• All employees / contractors / business partners are responsible for not facilitating tax evasion of taxpayers. Leadership / subject matter teams are responsible for ensuring FeRFA fulfils its key principles

• The Board of Directors are responsible for ensuring appropriate policies are in place and creating a culture that supports compliance.

When to speak up?

As an employee you commit to:

• Complying with this policy.

• Reporting any concerns

If you have a concern about any issues relating to our Corporate Criminal Offence policy performance or management arrangements, or you have a question about this policy you can speak to the policy owner or any of the following:

• Tell your manager

• Write to the Chief Executive Officer: tracey@ferfa.org.uk

Useful references

External:

Criminal Finances Act 2017, Corporate Criminal Offence of the Failure to Prevent the Criminal Facilitation of Tax Evasion.

Policy approved by the Ferfa Board of Directors 2024.

Corporate Social Responsibility

FeRFA recognise that while we are accountable, and we take into account the interests of all, including our employees, members, and suppliers temporary and agency staff and the wider community and environment within the countries in which we operate.

Framework of core business values:

• Corporate Conduct

• seek to be honest and fair in our relationships with our members
• provide the standards of products and services that have been agreed
• take all reasonable steps to ensure the safety and quality of the goods and services we provide
• seek to be honest and fair in our relationships with our suppliers
• have a policy not to offer, give or accept bribes, excess hospitality or substantial favors
• pay suppliers in accordance with agreed terms
• co-operate with members and suppliers to increase quality and efficiency
• encourage suppliers to abide by the principles of this Code
• Source goods and services from local businesses where possible.

• Care for well-being of employees

• provide clear and fair terms of employment
• provide clean, healthy, safe and secure conditions
• have a fair remuneration policy everywhere we operate
• strive for equal opportunities for all present and potential employees, temporary or agency staff and contractors
• encourage employees to develop skills and progress in their careers on fair assessment of performance and potential
• do not tolerate any sexual, physical or mental harassment including bullying or any other type of harassment of our employees, temporary or agency staff and contractors
• do not discriminate on grounds of colour race, ethnic origin, gender, age, religion, political or other opinion or beliefs, disability or sexual orientation
• do not employ underage staff or forced labour
• respect human rights within our responsibility and contractual obligations
  
  

• Social responsibility to the community

• respect the laws, culture, and international treaties of the home and overseas markets we serve
• aim to make the communities in which we work better places to live and do business
• Support local charitable organisations and undertake community investments programmes where possible.
• Employ local labour wherever possible.
• aim to be sensitive to the local community’s cultural, social and economic needs
• refrain from making association resources available to terrorists or rebels for political tribal and armed conflict

• Respect for the environment

• protect the environment with sound stewardship and practices
• Ensure all timber goods are sources from FSC or other similar scheme accredited suppliers and supported by chain of custody documentation.
• Reduce vehicle usage and fuel consumption where possible.
• Follow the waste management hierarchy as outlined in the Waste (England and Wales) Regulations 2011.

• Responsibility to shareholders and other suppliers of finance

• financially accountable to our board members
• maintain accurate records and prepare true and fair reports in line with reporting requirements
• communicate to board members all matters that are material to an understanding of the future prospects of the association
• aim to protect members funds, manage risks and ensure that funds are used as agreed

• Samples, Credit Notes, Gifts and Gratuities

• Any sample, gift, promotional item, gratuity or credit note offered by a supplier, member, or any other person must be accepted only on behalf of the association.  No employee has any authority to personally accept any gift, promotional item, gratuity, or credit note (however trifling) without prior approval from the CEO. Any breach of this Policy will be regarded by the association, subject to the usual Disciplinary Procedures, as gross misconduct.

• It is also prohibited for any employee to exchange any sample, gift or promotional item or credit note for any other form of stock for cash without prior approval in writing from the CEO.

• Approval in writing from the CEO or higher authority must be obtained prior to releasing, selling or disposing of any Association goods or property (excluding normal retail business).

Managing Director

FeRFA is committed to conducting its business responsibly and in accordance with the law and regulations.

All employees and agents acting on behalf of the association are expected to follow this Code. There are no exceptions. There are detailed policies and codes of conduct which reflect our position regarding each employee’s responsibility for helping preserve our reputation and to maintain compliance with applicable laws. However, these cannot address every issue which may arise. Each of us has an obligation to familiarise ourselves with applicable laws, association policies and practices, and to act responsibly, including taking advice if there is doubt on the appropriate course of action. All employees must take action to report potential or apparent violations of law, this Code, or any incident of questionable conduct to the CEO without delay.

Likewise, questions concerning responsible or legal conduct will inevitably arise in the normal course of business. It is the responsibility of each employee to contact the CEO before taking any action that may have legal consequences for the association or damage its reputation.

Malpractice and Maladministration

FeRFA recognises its obligation to the CITB as the awarding organisation, in respect of FeRFA-delivered qualifications, to ensure that the process of assessment and the integrity of its qualifications are preserved. Any attempt to undermine these will be investigated promptly and openly by FeRFA, according to the guidelines below.

Malpractice, which includes maladministration, means any act that compromises the integrity of the qualifications or that damages the authority, reputation or credibility of the awarding organisation or FeRFA. Failure to investigate allegations of suspected malpractice also constitutes malpractice.

For the purpose of this policy, this term also covers misconduct and forms of unnecessary discrimination or bias towards certain or groups of students.

Definitions

1. Student Malpractice: malpractice by a student in the course of any assessment, including the compilation of portfolios of assessment evidence. For example:

• the alteration or falsification of any results document, including certificates;
• a breach of the instructions or advice of an assessor, the qualification course leader, or the awarding organisation in relation to the assessment rules and regulations;
• collusion: working collaboratively with other students, beyond what is permitted;
• copying from another student (including the use of ICT to aid the copying);
• behaving in a way that enables the student to gain an unfair advantage;
• attempting to influence the assessment by offering incentives or by using threatening behaviour;
• allowing work to be copied e.g., posting written coursework on social networking sites prior to an assessment;
• the deliberate destruction of another student’s work;
• making a false declaration of authenticity in relation to the authorship of the contents of a portfolio;
• allowing others to assist in the production of the contents of a portfolio; and/or
• plagiarism: unacknowledged copying from published sources or incomplete referencing.
•  

• Centre Staff Malpractice: malpractice committed by a member of FeRFA as the CITB’s Authorised Training Organisation (ATO), including assessors for FeRFA-delivered qualification(s). For example:

discussing or otherwise revealing secure or privileged information in public, e.g., online forums;

• assisting or prompting students with the production of answers.
• tampering with a student’s work, or allowing a student’s work to be tampered with after collection and before despatch to the awarding organisation and/or assessor;
• attempting to influence the assessment by offering incentives or by using threatening behaviour; and/or
• publishing confidential information

• ATO Maladministration: failure to adhere to the regulations regarding the conduct of coursework or malpractice in the conduct of the assessments, mark sheets, cumulative assessment records, results and certificate claim forms, etc. For example:

• failing to issue to students the appropriate notices and warnings;
• failing to retain students’ assessments in secure conditions after the authentication statements have been signed or the work has been marked;
• failing to despatch portfolios for assessment to assessors and/or moderators in a timely way;
• failing to notify the CITB of an instance of suspected malpractice as soon as possible after such an instance occurs or is discovered;
• failing to conduct a thorough investigation into suspected malpractice when asked to do so by the CITB; and/or
• the inappropriate retention or destruction of certificates.

Reporting of suspected malpractice and maladministration

Cases of suspected malpractice and maladministration may be reported by a number of sources:

• FeRFA (via a written report);
• The student (via a written communication); and/or
• An assessor (via an assessor’s report).

Anonymous reports will not be accepted.

Investigation

Investigations will normally be carried out by FeRFA’s Chief Executive as the Head of the ATO and acting on behalf of the CITB, and they must be reported to the CITB when completed. The Head of the ATO must:

• notify the CITB at the earliest opportunity of all suspicions or actual incidents of malpractice. However, if malpractice is discovered in portfolios before the authentication form is signed, then this might be remedied by direct recourse to the student;

respond speedily and openly to all requests for an investigation into an allegation of malpractice, as this is in the best interests of ATO staff, students and any others involved;

• co-operate and ensure their staff co-operate fully with an enquiry into an allegation of malpractice, irrespective of whether the ATO is directly involved in the case;
• inform staff members and students of their individual responsibilities and rights as set out in these guidelines;
• submit full details of the case at the earliest opportunity to the CITB; and
• pass on to the individuals concerned any warnings or notifications of penalties and ensure compliance with any requests made by the awarding organisation as a result of a malpractice case.

Assessors who suspect malpractice in an assessment must notify FeRFA immediately. The investigator should:

• establish the full facts and circumstances of any alleged malpractice. It should not be assumed that because an allegation has been made, it is true; and
• provide the accused individual(s) with a completed copy of the form or letter used to notify the CITB of the malpractice.

The accused individual should:

• be informed in writing (email is acceptable) of the allegation made against them;
• know what evidence there is to support that allegation;
• know the possible consequences should malpractice be proven;
• have the opportunity to consider their response to the allegations (if required);
• have an opportunity to submit a written statement;
• have an opportunity to seek advice (as necessary) and to provide a supplementary statement (if required);

• be informed of the applicable appeals procedure, should a decision be made against them; and
• be informed which results will not be released until the investigation is complete (if a student).

Report

The Head of the ATO must submit a full written report of the case to the CITB. The report should be accompanied by the following documentation, as appropriate:

• a statement of the facts, a detailed account of the circumstances of the alleged malpractice, and details of any investigations carried out by the ATO;
• written statement(s) from the assessor, or other staff who are involved;
• written statement(s) from the student(s); and
• details of any mitigating factors.

Appeals Process

Students are entitled to appeal against student malpractice decisions. Students must make a written request for an appeal within 20 working days of receipt of the correspondence from FeRFA confirming the decision and penalties to be applied.

Students must provide a reason for requesting an appeal and pay the relevant fee. The current fees will be provided by FeRFA on request. Requests for appeals will be acknowledged by FeRFA within five working days and will be considered by a working group of FeRFA’s Board of Directors. Appeals will be considered by the working group within 20 working days.

The student will be notified of the working group’s decision within five working days of the meeting.

Outcome

If the investigation confirms that malpractice or maladministration has taken place, FeRFA will consider what action to take in order to:

• minimise the risk to the integrity of the qualification now and in the future;
• maintain public confidence in the delivery and awarding of qualifications;
• discourage others from carrying out similar instances of malpractice or maladministration; and
• ensure there has been no gain from compromising FeRFA’s standards.

Where staff or students have been found guilty of malpractice, the CITB may impose the following sanctions or penalties:

Staff Malpractice

• Written warning;
• Review and report (action plans);
• Additional monitoring or inspection;
• Removal of Direct Claims Status;
• Suspension of student registrations or entries;
• Suspension of certification;
• Withdrawal of approval for a specific qualification(s); and/or
• Withdrawal of ATO recognition.

Student Malpractice

• Written warning;
• Loss of marks for a section;
• Loss of all marks for a unit;
• Disqualification from a unit;
• Disqualification from a whole qualification; and/or
• Disqualification from all qualifications offered by the ATO.

FeRFA will undertake continuous monitoring to verify that actions resulting from episodes of malpractice or maladministration have been implemented and are not repeated.