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Policies and Statements

Gender Pay Gap Statement

Anti-Slavery and Human Trafficking Policy Health & Safety Policy

Gender Pay Gap Statement

As a forward looking organisation, strategically positioned to deliver for the current and future generations. We are proactively ensuring there is no pay gap between male and female employees doing the same job.

Actions taken to date include equal opportunities and unconscious bias awareness training, clear guidance on steps to promotion, mentoring and leadership programmes and enhancements to our flexible working policy.

We continually seek and partner wider initiatives which raise awareness about gender inequality. We are confident that women and men doing the same job at R Johnson are paid the same.

Anti-Slavery and Human Trafficking Policy

Slavery is defined as ownership exercised over a person or where individuals are coerced into providing their services or do so under threat of a penalty. Human trafficking is defined as arranging or facilitating the travel of individuals with a view to exploiting them.

Slavery and human trafficking are acknowledged to be a global problem. R Johnson is committed to taking steps to ensure that slavery and human trafficking are not taking place in our business or supply chains.

Our commitment to preventing slavery and human trafficking extends to all individuals working for R Johnson at all levels and grades, including Directors, senior managers, staff, consultants, contractors, seconded staff, agency staff, agents or any other person associated with us or any of our subsidiaries or their employees as part of our supply chain, in those locations where we have a studio.

R Johnson has a number of policies which aim to minimise the risk of modern slavery in our supply chain:

  • Responsible Procurement Policy
  • Anti-Bribery & Corruption Policy
  • Corporate Social Responsibility Policy
  • Equal Opportunities & Dignity at Work Policy

Due Diligence

Our procedures for selecting sub-consultants, service providers and suppliers align with our commitment to equality, diversity and human rights, including our commitment to ensuring that slavery and human trafficking does not take place within our business or supply chain.

We use pre-qualification checklists when selecting potential sub-consultants and suppliers and when reviewing our existing supply chain partners. The checklists align with our own values and standards, for example our sub-consultants’ pre- qualification checklist covers all aspects of policy and business activities, including specific questions relating to the Modern Slavery Act 2015. We also monitor our sub-consultants’ operations to ensure that they comply with the required standards.

In the event that a contractor, consultant, agency or other member of our supply chain was suspected of engaging in or supporting slavery or human trafficking an

investigation would be undertaken and, if necessary, our relationship with that supplier would terminate.

Action in this area would be driven by our Board of Directors.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in the organisation, R Johnson’s mandatory training programme includes an ‘Anti-Slavery and Human Trafficking Policy’ module. New starters and existing staff from all functions and locations are required to complete the training via an online training portal and any non-completion is followed up by senior management.

Responsibility for the Policy

For the purposes of this policy, the Quality Director will have primary responsibility for the regular review and update where appropriate.

This statement has been approved by R Johnson’s Board of Directors.

Health & Safety Policy

The Company aims to:

  • Carry out all activities in compliance with relevant statutory provisions
  • Provide a safe environment for our Employees and all those affected by our undertakings
  • Raise the profile in revitalising Health and Safety universally and promote commitment, control communication, co‐ordination and competency both internally and externally

The Directors and Senior Management shall:

  • “Implement the Company Health and Safety Policy
  • “Actively promote the safety culture within the company and with the companies with

which

we work

  • “Continually review and improve the Safety Arrangements and Procedures
  • “Afford relevant importance to Health and Safety considerations in planning all business activities
  • “Facilitate regular Employee consultation on Health and Safety matters
  • “Inform Employees and those under the Company’s direction, of the statutory obligation to

work safely without risk to themselves or others, both in the Company Offices and whilst working on or visiting sites

  • “Provide relevant information and resources for ongoing training of employees in matters of

Health and Safety

  • “Ensure that our Policy and Safety Arrangements are made available/accessible to all

our

Employees

Policy statements also address:

Worksafe, or Refusal to Work

Through the promotion of continuous improvement, the Policy will be updated and reviewed at least annually, or as and when it is deemed necessary, to reinforce the Company’s attitude to Health and Safety and any changes shall be communicated to those affected.

Anti-Bribery Policy

Scope of Policy

This policy applies to all individuals working within and for the R Johnson Ltd at all levels and grades, including Directors, senior managers, staff, consultants, contractors, seconded staff, agency staff, agents or any other person associated with us or any of our subsidiaries or their employees, wherever located.

Every employee or person acting for or on behalf of R Johnson is responsible for maintaining the highest standards of business conduct. Any breach of this policy will be regarded as a serious disciplinary, contractual and potentially criminal matter for the individual concerned as this in turn may cause serious damage to the reputation of R Johnson.

UK Bribery Act 2010

R Johnson is committed to comply with the UK Bribery Act across all its business activities as a global minimum standard, with local legislation taking precedence if it requires compliance with even higher standards. There are four main offences under the Act:

  • Offering bribes;
  • Receiving bribes;
  • Bribing foreign public officials;
  • A corporate offence of failing to prevent bribery.

Under the Act a bribe is a financial or other type of advantage that is offered or requested with the:

  • intention of inducing or rewarding illegal or unethical performance of a function or activity; or o belief or knowledge that accepting such an advantage would constitute the illegal or unethical performance of such a function or activity.

Function or activity in these terms includes public, state or business activities or any activity performed in the course of a person’s employment, or on behalf of another company or individual, where the person performing that activity is expected to perform it in good faith, impartially, or in accordance with a position of trust.

All R Johnson employees and those persons acting on behalf of R Johnson are required to adhere to this policy and act in compliance with the UK Bribery Act.

Our Principles

It is our policy to conduct all of our business in an honest and ethical manner. We take a zero tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate.

It is our best practice objective that those we do business with take a similar zero- tolerance approach to bribery and corruption.

We are bound by the laws of the UK, including the Bribery Act 2010 as a global minimum, in respect of our conduct both at home and abroad. We must also comply with laws relevant to countering bribery and corruption in each of the jurisdictions in which we operate.

Bribery and corruption are criminal offences and, under the UK Bribery Act, are punishable for individuals by up to ten years’ imprisonment and an unlimited fine; if the Company is found to have taken part in corruption it could face an unlimited fine, be excluded from tendering for public contracts and face serious damage to its reputation. We therefore take our legal responsibilities very seriously and expect those working within or for the business to do the same.

In this policy “third party” means any individual or organisation we come into contact with during the course of our work, and includes actual and potential customers, suppliers, distributors, business contacts, agents, advisers, government and public bodies, including their advisors, representatives and officials, politicians and political parties.

This policy does not prohibit

  • Normal or appropriate hospitality and entertainment with clients; and
  • The use of any recognised fast-track process that is publicly available on payment of a fee.

It is important that all such practices are proportionate, reasonable and made in good faith. Clear records must be kept at all times.

This policy should be read in conjunction with the relevant employment conditions set out under the heading of Working at R Johnson on our company intranet, Planet, or local employee policies or handbooks.

Working Internationally

R Johnson employees, or those representing R Johnson who are involved in business outside of their domestic markets may, through unfamiliarity, be more at risk of being exposed to bribery or unethical business conduct. All those who function in this capacity are required to work within R Johnson’s risk management

procedures and keep the local Directors fully informed of any actual or suspected bribery.

In particular the following should be reported:

  • requests for cash payments whether direct or via a third party
  • reimbursement of unsubstantiated expense whether direct or via a third party
  • personal or business ties that an employee, representative or joint venture partner may have

with government or corporate officials, directors or employees

  • history of corruption in the country in which the work is being undertaken o

lack of invoices and acceptable financial practices.

Risk Management

Effective risk assessment lies at the core of the success or failure of this policy. Risk identification will pinpoint the specific areas in which we face bribery and corruption risks and this will allow us to better evaluate and mitigate these risks and thereby protect ourselves. Business practices around the world can be deeply rooted in the attitudes, cultures and economic prosperity of a particular region – any, or all, of which can vary. Local Management must assess the vulnerability of each business unit to these risks on an ongoing basis, subject to review by Board of Directors.

Many serious global bribery and corruption offences have been found to involve some degree of inaccurate record-keeping. We must ensure that we maintain accurate books, records and financial reporting within all R Johnson business units and for significant business partners working on our behalf. Our books, records and overall financial reporting must also be transparent. That is, they must accurately reflect each of the underlying transactions. False, misleading or inaccurate records of any kind could potentially damage R Johnson.

All R Johnson business locations must maintain an effective system of internal control and monitoring of our transactions. Once bribery and corruption risks have been identified and highlighted via the risk assessment process, procedures can be developed within a comprehensive control and monitoring programme in order to help mitigate these risks on an ongoing basis.

Each Director must ensure that local management engages in effective risk assessment and implements the necessary steps to prevent bribery and corruption. As these steps will vary by geography and business unit, Directors should consult with the Directors, who will make available guidelines, principles and methodologies for the identification, mitigation and monitoring of these risks.

Records

R Johnson will keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

All employees and those representing R Johnson must ensure that all expense claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance the established expense policies of the relevant business units. Particular attention should be paid to the recording of the reasons for expenditure.

All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as customers, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept outside of R Johnson’s recognised accounting system to facilitate or conceal illegal or unethical payments.

Facilitation Payments

R Johnson does not allow its employees or its representatives to make, or accept, facilitation payments of any kind. Facilitation payments are usually small payments (or gifts) made to public officials in order to speed up or facilitate actions that the officials are already duty bound to perform. R Johnson makes no distinction between facilitation payments and bribes regardless of their size or the local culture and under the UK Bribery Act it constitutes a criminal offence by both the individual and the Company.

R Johnson employees and representatives are required to act with greater vigilance when dealing with unfamiliar international government procedures. If you are asked to make a payment on our behalf you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the

reason for the payment. If you have any suspicions, concerns or queries regarding payment you should raise these with the Director responsible.

Whilst UK law prohibits facilitation payments or kickbacks and you are not required to place your life or liberty at risk. Any such incidents should be reported immediately to the Director responsible at the first available opportunity.

Corporate Entertainment, Gifts, Hospitality and Promotional Expenditure

Gifts, entertainment, hospitality and promotional expenditure includes both the receipt and offer of gifts, meals or tokens of appreciation and gratitude, or invitations to events, functions, or other social gatherings, in connection with matters related to our business. These are acceptable provided they fall within reasonable bounds of value and occurrence.

R Johnson permits corporate entertainment, gifts, hospitality and promotional expenditure that is undertaken:

  • for the purpose of establishing or maintaining good business relationships; o

to improve the image and reputation of R Johnson, or

  • to present R Johnson services effectively. This is conditional on it:
  • being arranged in good faith, and
  • not offered, promised or accepted to secure an advantage for R Johnson or its employees or

representatives or to influence the impartiality of the recipient.

R Johnson will authorise only reasonable, appropriate and proportionate entertainment and promotional expenditure.

This principle applies to employees and those representing R Johnson whether based in or outside the UK. However those with international remits may require further guidance and training in the ways local markets operate. It will be the responsibility of the local Directors to ensure that their staff are fully informed.

Political Donation

R Johnson does not make contributions to political parties. R Johnson only makes charitable donations that are legal and ethical under local laws and practices.

Reporting Suspected Bribery

R Johnson depends on its employees and associated persons to ensure that the highest standards of ethical conduct are maintained in all its business dealings. Employees and associated persons are requested to assist the Company and to remain vigilant in preventing, detecting and reporting bribery.

Employees and associated persons are encouraged to report any concerns that they may have to the Directors as soon as possible. Issues that should be reported include:

  • any suspected or actual attempts at bribery;
  • concerns that other employees or associated persons may be being bribed; or
  • concerns that other employees or associated persons may be bribing third parties, such as

clients or government officials.

Action by the Company

R Johnson will fully investigate any instances of alleged or suspected bribery. Employees suspected of bribery may be suspended from their duties while the investigation is being carried out. The Company will invoke its disciplinary procedures where any employee is suspected of bribery, and proven allegations may result in a finding of gross misconduct and immediate dismissal. R Johnson may terminate the contracts of any associated persons, including consultants or other workers who act for, or on behalf of, the Company who are found to have breached this policy.

R Johnson may also report any matter to the relevant public and/or legal authorities. R Johnson will provide all necessary assistance to the relevant authorities in any subsequent investigation and potential criminal prosecution.

Review of Procedures and Training

R Johnson will regularly review and update its Anti-Bribery and Corruption policy and communicate this to all employees and those representing the Company. R Johnson will incorporate this policy into the induction of new staff and the Process Director will arrange training sessions as required for all employees including Directors who are responsible for the implementation of the policy.

R Johnson will monitor the effectiveness and review the implementation of this policy, considering its suitability, adequacy and effectiveness. Improvements identified will be made as soon as possible.

All employees or those representing R Johnson are responsible for the success of this policy and should ensure they use it to disclose any actual or suspected danger of wrongdoing, illegal or unethical function or activity.

Employees are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Process Director

R Johnson reserves the right to vary and/or amend the terms of this policy from time to time at its absolute discretion

Statement of Commitment

R Johnson takes a zero-tolerance approach to bribery and corruption and we are committed to conducting our business, wherever in the world, in an honest and ethical manner. It will be regularly reviewed and amended or updated as necessary to reflect changing circumstances. We have adopted this policy to communicate this message and to assist the whole of R Johnson to uphold it through compliance with rules and guidance as set out.

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