Terms and Conditions

Equal Opportunities and Diversity

What this policy covers

This policy applies to employees, workers, and contractors.

The Company recognises the benefits of a diverse workforce and is committed to providing a working environment that is free from discrimination.

The Company will seek to promote the principles of equality and diversity in all its dealings with employees, workers, job applicants, clients, customers, suppliers, contractors, recruitment agencies and the public.

Everyone who acts on the Company’s behalf is required to adhere to this policy when undertaking their duties or when representing the Company in any other guise.

Your entitlements and responsibilities

Unlawful discrimination

Unlawful discrimination of any kind in the working environment will not be tolerated and the Company will take all necessary action to prevent its occurrence. 

Specifically, the Company aims to ensure that no employee, worker or job applicant is subject to unlawful discrimination, either directly or indirectly, on the grounds of gender, gender reassignment, race (including colour, nationality, caste and ethnic origin), disability, sexual orientation, marital status, part-time status, pregnancy or maternity, age, religion or belief, political belief or affiliation or trade union membership. This commitment applies to all aspects of employment, including:

• recruitment and selection, including advertisements, job descriptions, interview and selection procedures
• training
• promotion and career-development opportunities
• terms and conditions of employment, and access to employment-related benefits and facilities
• grievance handling and the application of disciplinary procedures
• selection for redundancy

Equal opportunities practice is developing constantly as social attitudes and legislation change. The Company will review all policies and implement necessary changes where these could improve equality of opportunity.

Career development

While positive measures may be taken to encourage under-represented groups to apply for employment opportunities, recruitment or promotion to all jobs will be based solely on merit.

Everyone will have equal access to training and other career-development opportunities appropriate to their experience and abilities.

However, the Company will take appropriate positive action measures (as permitted by equal opportunities legislation) to provide specialist training and support for groups that are under-represented in the workforce and encourage them to take up training and career development opportunities.

Procedure

Complaints of discrimination

The Company will treat seriously all complaints of discrimination made by employees, clients, customers, suppliers, contractors or other third parties and will take action where appropriate.

If you believe that you have been discriminated against, you are encouraged to raise the matter as soon as possible with your manager or other senior manager using the Company’s Grievance Procedure (outlined elsewhere in the Employee Handbook).

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

Investigating accusations of unlawful discrimination

If you are accused of unlawful discrimination, the Company will investigate the matter fully.

During the course of the investigation, you will be given the opportunity to respond to the allegation and provide an explanation of your actions.

If the investigation concludes that the claim is false or malicious, the complainant may be subject to disciplinary action.

If the investigation concludes that your actions amount to unlawful discrimination, you will be subject to disciplinary action, up to and including dismissal without notice for gross misconduct.

Equal Opportunities Monitoring

The Company may carry out monitoring for the purposes of measuring the effectiveness of its equal opportunities and diversity policy.

Health & Safety Policy

The health and safety of our employees, contractors, and visitors is a priority for Seal Packaging and we are committed to providing a safe and healthy workplace and continuously improving our health and safety performance.

Whilst compliance with legal obligations in the jurisdictions in which we operate is our minimum commitment, we also seek to identify and share best practices across our businesses to ensure all our major risks are addressed.

We implement management systems to ensure we comply with health and safety legislation and continually improve our health and safety performance. Our health and safety management systems will cover at a minimum:

Warehousing and vehicle safety: Due to these activities being outsourced to a third party, Seal Packaging Ltd has not health and safety requirements for these areas.

Business areas should:

• Carry out audits on compliance with the Company’s health and safety standards and applicable regulatory requirements. Criteria for selection and prioritisation of locations to be audited should be established.
• Establish objectives for the improvement of health and safety performance and allocation of adequate budget for the achievement of these objectives.
• Implement a process to review and report lost time accidents and other specified safety performance indicators to the Group in line with agreed deadlines.
• Nominate a representative with the responsibility to coordinate health and safety matters in the business area.

Businesses should:

• Identify health and safety risks associated with their activities (risk assessment)
• Implement health and safety management systems and safe working procedures, covering at a minimum the group safety standards, any additional safety risks as identified by risk assessments and applicable legislative requirements. Where appropriate these management systems should be externally certified, such as ISO 45001.
• Communicate health and safety requirements to employees and provide appropriate training to apply safe working procedures.
• Investigate accidents, incidents, and near misses to drive improvement of health and safety management.
• Report lost time accidents and other specified safety performance indicators in the reporting system. Policy Ownership and monitoring The health and safety policy and the associated health and safety standards are owned by the Company HR director. The policy and standards are subject to review and revision on an ongoing basis. A formal review of the policy of the standards will be carried out at a minimum every three years by the Corporate Responsibility Committee (CRC). The compliance with the requirements of the Health and safety policy and standards is monitored by CRC. This includes a quarterly review of
• The business area health and safety audit programs and the audit results.
• Progress against targets to improve key health and safety performance indicators.
• Serious accidents.
• Business area commentary. The health and safety performance on the Business area level is quarterly reported by the HR director to the Board. This report includes a description of serious accidents and a summary of the key health and safety performance indicators.

Harassment & Bullying

What this policy covers

This policy applies to employees, workers and contractors.

This policy details your rights and obligations in relation to your personal data and the personal data of third parties that you may come into contact with during the course of your work.

“Personal data” is any information that relates to a living individual who can be identified from that information.

“Processing” is any use that is made of personal data, including collecting, storing, amending, disclosing or destroying it.

“Special categories of personal data” means information about an individual’s racial or ethnic origin, political opinions, religious or political beliefs, trade union membership, health, sex life or sexual orientation and biometric data.

“Criminal records data” means information about an individual’s criminal convictions and offences and information relating to criminal allegations and proceedings.

If you have access to the personal, special categories or criminal records data of staff or of third parties, you must comply with this Policy.  Failure to comply with the Policy and procedures may result in disciplinary action up to and including dismissal without notice.

Data Protection principles

The Company processes HR-related personal data in accordance with the following data protection principles:

• the Company processes personal data lawfully, fairly and in a transparent manner;
• the Company collects personal data only for specified, explicit and legitimate purposes;
• the Company processes personal data only where it is adequate, relevant and limited to what is necessary for the purposes of the processing;
• the Company keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay;
• the Company retains personal data only for the period necessary for the processing;
• the Company adopts appropriate measures to make sure that personal data is secure and is protected against unauthorised or unlawful processing and from accidental loss, destruction or damage.

Your entitlements

Data protection legislation prescribes the way in which the Company may collect, retain and handle personal data.  The Company will comply with the requirements of data protection legislation and anyone who handles personal data in the course of their work must also comply with it.

The Company will inform individuals of the reasons for processing their personal data, how it uses such data and the legal basis for processing in its privacy notices. It will not process personal data about individuals for other reasons.

Where the Company processes special categories of personal data or criminal records data to perform obligations or to exercise rights in employment law, this is done in accordance with the rules relating to special categories of data and criminal records data.

The Company will update HR-related personal data promptly if an individual advises that their information has changed or is inaccurate.

Personal data gathered during the employment or engagement of an employee, worker, contractor, volunteer, or intern is held in the individual’s personal file (in hard copy or electronic format, or both), and on HR systems. The periods for which the Company holds HR-related personal data are contained in its privacy notices.

Access to your personal data [subject access requests]

You have the right to make a subject access request. If you make such a request, the Company will tell you:

• whether or not your data is processed and if so why; the categories of personal data concerned and the source of the data if it is not collected from you;
• to whom your data may be disclosed, including any recipients located outside the European Economic Area (EEA) and the safeguards that apply to any such transfers;
• for how long your personal data is stored or how that period is decided;
• your rights to rectification or erasure of data, or to restrict or object to processing;
• your right to complain to the Information Commissioner if you think the Company has failed to comply with your data protection rights; and
• whether or not the Company carries out any automated decision-making and the logic involved in such decision-making.

The Company will also provide you with a copy of the personal data undergoing processing. This will normally be in electronic form if you have made the request electronically, unless you request otherwise.

If you want additional copies, the Company will charge a fee, which will be based on the administrative cost of providing the additional copies.

Other rights

You have a number of other rights in relation to your personal data. You can require the Company to:

• rectify inaccurate data;
• stop processing or erase data if your interests override the Company’s legitimate grounds for processing data (where the Company relies on its legitimate interests as a lawful basis for processing data);
• stop processing or erase data if it is unlawful; and
• stop processing data for a period if it is inaccurate or if there is a dispute about whether or not your interests override the Company’s legitimate interests for processing the data.

Your responsibilities

You are responsible for helping the Company keep your personal data accurate and up to date. You should let the Company know if personal data provided to the Company changes, for example, if you change bank or move house.

You may have access to the personal data of other individuals and of our customers or clients in the course of your employment, contract, volunteer period, internship or apprenticeship. Where this is the case, the Company relies on you to help meet its data protection obligations.

If you have access to personal data, you are required:

• to access only data that you have authority to access and only for authorised purposes;
• not to disclose data except to individuals (whether inside or outside the Company) who have appropriate authorisation;
• to keep data secure (for example by complying with rules on access to premises, computer access including password protection, and secure file storage and destruction);
• not to remove personal data or devices containing or that can be used to access personal data, from the Company’s  premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device; and
• not to store personal data on local drives or on personal devices that are used for work purposes.

Failure to observe these requirements may amount to a disciplinary offence which will be dealt with under the Company’s disciplinary procedure. Significant or deliberate breaches of this policy, such as accessing employee, customer or client data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to your dismissal without notice.

Processing special categories and criminal records data

The Company will process special categories and criminal records data primarily where it is necessary to enable the Company to meet its legal obligations and in particular to ensure adherence to health and safety legislation; vulnerable groups protection legislation; or for equal opportunities monitoring purposes.

Procedure

The Company keeps a record of its processing activities in respect of HR-related personal data in accordance with the requirements of data protection legislation.

Personal data relating to staff may be collected by the Company for the purposes of:

• recruitment,  promotion, training, redeployment and/or career development, such as references, CVs and appraisal documents;
• administration and payment of wages, such as emergency contact details and bank/building society details;
• calculation of certain benefits including pensions;
• disciplinary or grievance issues;
• performance management purposes and performance review;
• recording of communication with staff and their representatives;
• compliance with legislation;
• provision of references to financial institutions, to facilitate entry onto educational courses and/or to assist future potential employers; and
• staffing levels and career planning

How we use special categories and criminal records data

“Special categories” data and “criminal records” data require higher levels of protection. We need to have further justification for collecting, storing and processing these types of personal data. We may process special categories or criminal records data in the following circumstances:

• in limited circumstances, with your explicit written consent;
• where we need to carry out our legal obligations;
• where it is needed in the public interest, such as for equal opportunities monitoring, or in relation to our occupational pension scheme;
• where it is needed to assess your working capacity on health grounds.

Less commonly, we may process this type of data where it is needed in relation to legal claims or where it is needed to protect your vital interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Accuracy of personal data

The Company will review personal data regularly to ensure that it is accurate, relevant and up to date.

To ensure the Company’s files are accurate and up to date, and so that the Company is able to contact you or, in the case of an emergency, another designated person, you must notify the Company as soon as possible of any change in your personal details (e.g. change of name, address, telephone number, loss of driving licence where relevant, next of kin details, etc).

Security of personal data

The Company will ensure that personal data is not processed unlawfully, lost or damaged.  If you have access to personal data during the course of your employment, you must also comply with this obligation.  If you believe you have lost any personal data in the course of your work, you must report it to your manager immediately.  Failure to do so may result in disciplinary action up to and including dismissal without notice.

Data breaches

The Company will record all data breaches regardless of their effect.

If we discover that there has been a breach of HR-related personal data that poses a risk to the rights and freedoms of individuals, we will report it to the Information Commissioner within 72 hours of discovery.

If the breach is likely to result in a high risk to the rights and freedoms of individuals, we will tell affected individuals that there has been a breach and provide them with information about the likely consequences of the breach and the mitigation measures we have taken.

Access to personal data [“subject access requests”]

To make a subject access request, you should send your request to the Company. In some cases, the Company may need to ask for proof of identification before the request can be processed. We will inform you if we need to verify your identity and the documents we require.

We will normally respond to a request within one month from the date we receive it. In some cases, such as where the Company processes large amounts of the individual’s data, we may respond within three months of the date the request is received. We will write to the individual within one month of receiving the original request to tell them if this is the case.

If a subject access request is manifestly unfounded or excessive, the Company is not obliged to comply with it. Alternatively, we can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which we have already responded. If you submit a request that is unfounded or excessive, we will notify you that this is the case and whether or not we will respond to it.

Ethical Policy

Policy Statement

Seal Packaging Ltd. recognises that its commercial activities have the potential to impact on our customers and suppliers and therefore they have a right to expect:

• Products manufactured and sourced by the Company are produced under working conditions that are hygienic and safe.

• All workers involved in the production and supply of our products are treated with full consideration to their basic human rights.

• The Company acts in an ethical manner above that required by basic legal requirements.

Seal Packaging Ltd. is committed to following and implementing the principles of the Ethical Trading Initiative Base Code (although we are not members of the ETI).

This policy sets out the measures being taken to ensure that Seal Packaging UK Ltd. is acting in an ethical manner.

2 Seal’s Commitment to its suppliers, service providers, and customers:

We recognise that our ethical and social performance and reputation is a key part of our overall commercial success and will endeavour to continue and enforce the policy principles.

Employees

We are committed to ensuring that our employment practices and the enforcement of corporate regulations ensure the protection of the rights of all those who work for us.  In many areas we aim to operate above the minimum standards required by law to ensure our employees are safe, rewarded and valued. 

Customers

We are committed to demonstrating our ethical and social responsibility credentials to enable customers to make informed choices about products they purchase.

Suppliers

We are committed to monitoring social standards in the supply chain, and the company encourages suppliers to operate to the same ethical standards employed by us.

The ethical trading practices of direct suppliers are initially monitored by self-assessment questionnaires, as risk assessment requires.  As a minimum direct suppliers are required to comply with or have time defined plans to adopt ethical trading standards based on the ETI base code at their own manufacturing and supply sites, and to drive Ethical Trading requirements along their own supply chain.

3.         Seal Packaging Ltd.’s Ethical Trading Code of Practice

3.1       This Code of Practice applies to:

• Staff directly employed by us on temporary or permanent contracts.
• Staff employed or provided by employment agencies to work on Company premises.

3.2       No forced, bonded or involuntary labour shall be used.

• All employment with us is freely chosen.
• Staff are not required to lodge deposits or identity papers with us.
• Staff are free to leave after reasonable notice.

3.3       No child labour shall be used.

• There shall be no recruitment of child labour.
• Young persons under the age of 18 are not employed at night or required to undertake hazardous activities.

3.4       All employees have the right to join a recognised trade union.

• We have an open attitude towards the activities of trade unions.
• Union representatives are able to carry out their activities without hindrance.

3.5       Working conditions are safe and hygienic.

• We take adequate measure to prevent accidents and minimise potential hazards.
• Staff receive health & safety training.
• Staff have unrestricted access to toilet facilities and drinking water.
• We have published a Health & Safety Policy.

3.6  Working hours and remuneration are reasonable and comparable to other companies within the manufacturing industry, and regular employment is provided.

• Staff pay rates comply with national legal standards as a minimum.
• Staff are not forced to work in excess of 48 hours per week on a regular basis, and are provided with at least 1 day off per week.  All overtime is voluntary.
• Staff are given written terms and conditions of employment that details the employment relationship between, and the respective obligations of, the employee and employer, rates of pay, working hours, grievance and disciplinary procedures, holiday entitlement, absence & sick pay rules and notice periods for termination of employment.
• No deductions are made from wages as a disciplinary measure, and pay slips detailing lawful deductions (tax, national insurance) and voluntary deductions (pension, charity donations, social club) are provided each pay period.
• Sub-contracting and fixed term contracts are not used as a means to avoid obligations under labour or social security laws

3.7       No discrimination is practised.

• There is no discrimination in pay, hiring, compensation, access to training, promotion, and termination of employment or retirement on the grounds of race, nationality, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.
• Opportunities for personal and career development are equally available to all employees.

3.8       No Harassment, threats, abuse or intimidation shall be practiced.

• Physical, verbal and sexual threats, abuse, harassment or intimidation is expressly prohibited.

4.         Employment Agencies

4.1       Employment agencies contracted to supply temporary staff shall demonstrate commitment to application of the requirements of this code.

4.2    Employment agencies contracted to supply temporary staff shall ensure that all staff supplied to the Company are eligible to work in the United Kingdom and Ireland by:

• Following Immigration and Nationality Directorate Guidelines on Amendments to Section 8 of the Asylum and Immigration Act 1996.
• Ensuring that the requirements of the Immigration and Asylum Act 1999 Section 22 Code of Practice are met.
• Retaining copies of identity papers, work permits or passport stamps as detailed in the Home Office List of Specified Documents and UK Passport Stamps.

4.3       Employment agencies contracted to supply temporary staff shall ensure that all staff supplied to us have sufficient command of English to understand:

• The agency’s responsibilities under this code of practice.
• Our Health & Safety requirements.
• Our Hygiene requirements

5.     Organisation and Responsibility

Seal Packaging Ltd. Directors have overall responsibility for the ethical trading at work within their areas of control.

The Human Resources Officer will take the lead in planning, developing, reviewing and communicating the ethical trading policy and standards and ensuring improvement action is taken where necessary, to ensure the policy is adhered to within the company.

The Compliance Department is responsible for ensuring that all suppliers operate the same ethical standards by way of questionnaires, identifying and investigating any incidents or non-conformances and taking corrective action.

All Managers and Supervisors are responsible for promoting ethical working practices and following appropriate procedures.  They will also ensure that any incidents or non-conformances against this policy are reported to either the Human Resources or Compliance Departments.

Each Employee also has a duty to co-operate with management so far as is necessary to enable them to fulfil their statutory obligations.  This includes:

• Co-operating in the introduction and operation of all measures designed to fulfil management’s obligations under this policy.
• Drawing attention to actual or potential problems.
• Suggesting ways in which ethical trading practices could be improved.