The following sets out various policies held by Grant Associates which are reviewed annually.
Data Protection Act Policy
Grant Associates are committed to:
- ensuring that we comply with the eight data protection principles, as listed below
- meeting our legal obligations as laid down by the Data Protection Act 1998
- ensuring that data is collected and used fairly and lawfully
- processing personal data only in order to meet our operational needs or fulfill legal requirements
- taking steps to ensure that personal data is up to date and accurate
- establishing appropriate retention periods for personal data
- ensuring that data subjects’ rights can be appropriately exercised
- providing adequate security measures to protect personal data
- ensuring that a nominated officer is responsible for data protection compliance and provides a point of contact for all data protection issues
- ensuring that all staff are made aware of good practice in data protection
- ensuring that everyone handling personal data knows where to find further guidance
- ensuring that queries about data protection, internal and external to the organisation, is dealt with effectively and promptly
- regularly reviewing data protection procedures and guidelines within the organisation.
Data protection principles
Personal data shall be processed fairly and lawfully.
- Personal data shall be obtained for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes.
- Personal data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed.
- Personal data shall be accurate and, where necessary, kept up to date.
- Personal data processed for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
- Personal data shall be processed in accordance with the rights of data subjects under the Data Protection Act 1998.
- Appropriate technical and organisational measures shall be taken against unauthorised and unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.
- 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.
Corporate Responsibility Statement
Grant Associates recognises that responsible and sustainable corporate performance is essential to the long term success of our business and benefit to all of our clients. We adhere to the following principles:
Environment & Sustainability
- Grant Associates’ approach is based on the philosophy of sustainable development. We endeavour to work only on projects built around a concern for social and environmental quality.
- Grant Associates has a clearly defined environmental policy that is applied to both day today office management and the way it approaches projects.
- Grant Associates has a defined reduce and recycle policy and has a selective purchasing strategy that favours products that are low energy, use of recycled materials and which are local, organic/or ethically sound.
Integrity & Ethics
- Grant Associates maintain the highest standards of corporate governance.
- Grant Associates deal fairly with all suppliers, partners, clients and other parties we encounter in our business and we develop productive and collaborative relationships.
- Grant Associates ensure bids are conducted with integrity and transparency.
- Grant Associates apply and continuously seek to improve our risk management procedures and protocols.
- Grant Associates is committed to a comprehensive policy of equal opportunities in employment in which individuals are selected and treated on the basis of their relevant merits and abilities.
- Grant Associates is committed to offer training and development opportunities to all employees equally and without prejudice. The Company supports the CPD requirements set out by the Landscape Institute.
Health & Safety
- Grant Associates has a comprehensive Health and Safety Policy and is committed to continuous improvement in this area. Grant Associates employs external health and safety consultants to audit and advise the company.
- Grant Associates supports the development of local businesses, cultural events and uses local people and other local resources wherever possible. Grant Associates has been a sponsor of the annual Bath Fringe Festival and creates the annual Forest of the Imagination events.
- Grant Associates positively encourages feedback from clients, contractors and those in contact with Grant Associates, as a necessary part of a review process to ensure services are maintained or improving.
Bribery & Corruption Policy
Grant Associates is dedicated to ensuring full compliance with all anti-bribery and corruption laws and regulations, including the Bribery Act 2010. Its Anti-Bribery Policy extends to all the Company’s business dealings and transactions.
Grant Associates’ policy is that no employee; associate or agent shall pay bribes or offer improper inducements to anyone for any purpose, nor do we or will we, accept bribes or improper inducements. Grant Associates expects its employees to demonstrate honesty; integrity and fairness in all aspects of their business dealings and exercise appropriate standards of professionalism and ethical conduct in all their activities.
To use a third party as a conduit to channel bribes to others is a criminal offence. We do not; and will not, engage indirectly in or otherwise encourage bribery.
Grant Associates takes bribery and corruption very seriously; and will not tolerate bribery or corruption in any form and has a ‘zero tolerance’ approach to any breach of this policy. All directors and employees of Grant Associates are required to comply with the policy.
Grant Associates encourages its employees to report any suspicious activity that may violate this policy.
Competition Law Compliance Policy
Grant Associates is committed to compliance in full with all laws and regulations, including competition laws. Grant Associates adheres to the principle of fair and efficient competition and does not engage in conduct which is anti-competitive- such as entering into agreements which restrict, prevent or distort competition.
To comply with competition laws, Grant Associates should seek to bid for contracts independently from, and without any agreement or arrangement with, its competitors. The only exception to this is if neither Grant Associates nor the competitor would have a good chance of winning the bid on its own because it is not big enough or does not have all the requisite skills. In such circumstances Grant Associates may enter into a joint venture arrangement for the purposes of submitting a joint bid with one or more of its competitors – provided always that cooperation is strictly limited to that which is necessary for the purposes of the joint bid.
Acting independently means not engaging in agreements regarding the pricing, bids or bidding strategies.
This includes not:
- Discussing any element of pricing (e.g profit margins, labour costs) or engaging in cover pricing or price fixing.
- Discussing restrictions on geographic markets, customers or terms and conditions of contract with competitors.
- Engaging in methods of keeping new competitors cut out of the market.
- Discussing sub-contractor or suppliers arrangements with competitors.
- Engaging in bid rotation or bid suppression.
- Engaging in sub-contract bid rigging.
Grant Associates considers a breach of this policy as a serious offence. Any violation will result in disciplinary action, up to and including dismissal of an individual in appropriate circumstances. Breach of competition laws may also lead to penalties including fines and/or imprisonment being enforced against the individual by the regulator.
Modern Slavery & Human Trafficking Policy
Grant Associates is committed to driving out acts of modern day slavery and human trafficking within its business and that from within its supply chains, including sub-contractors, and partners. The Company acknowledges responsibility to the Modern Slavery Act 2015 and will ensure transparency within the organisation and with suppliers of goods and services to the organisation. These as well as the suppliers of services make up the supply chain within Grant Associates.
As part of the companies due diligence supplier approval process will incorporate a review of the controls undertaken by the supplier to prevent slavery and human trafficking. Imported goods from sources outside the UK and EU are potentially more at risk for slavery/human trafficking issues. The level of management control required for these sources will be continually monitored.
The company will not support or deal with any business knowingly involved in slavery or human trafficking.
The company Directors and senior management shall take responsibility for implementing this policy statement and its objectives and shall provide adequate resources (training, etc ) and investment to ensure that slavery and human trafficking is not taking place within the organisation and within its supply chains.
A full copy of this policy and a copy of the Modern Slavery Act 2015 will be accessible to all employees electronically and can be obtained from the HR department upon request.
This policy statement will be reviewed annually.