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Privacy and Customer Care Policies

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DATA PROTECTION AND INFORMATION SECURITY POLICY

Privacy Notice 25th May 2018

To all Employees, Suppliers, Clients and Customers and any other Stakeholders working on behalf of, or in collaboration with, Bell Group U.K. Limited (hereon in referred to as “Bell Group”), including all wholly owned subsidiaries; Bell Decorating Group Limited, P&D Scotland Limited, Torbay Decorating Company Limited, Abco Management Limited, Paint My Home and Cyril John Limited.
As our valued employees, clients, customers, subcontractors and suppliers, we want to keep you up to date with the steps Bell Group and our subsidiaries are taking to demonstrate our commitment to complying with the General Data Protection Regulations and the Data Protection Act 2018, which came in to effect as of the 25th May 2018. GDPR imposes additional obligations on organisations and gives individuals extra rights around how your data is used.
Looking after the personal information you share with us is very important. We want you to be confident that your personal data is kept safely and securely and to understand how we use it to offer a better and more personalised service.
It is our goal to be as open and transparent as possible and this Data Protection and Information Security Policy provides more information on the data we hold, what we do with that data, who we share the data with and your new rights under GDPR.
If we make changes to our Privacy Policy, we will notify you by updating it on our website. Should you need to contact us, please write to our HR Manager and Data Protection Champion:
Paramjit Barry, Bell Group UK Limited, Bell Business Park, Rochsolloch Road, Airdrie, ML6 9BG

Email via HR@bellgroup.co.uk quoting Security and Privacy Enquiry.
Kind Regards,

The Bell Group Data Protection Team

Customer Care Policy

POLICY STATEMENT
Paint My Home Quality Focus
Paint My Home is committed to providing the highest quality of service to our customers, utilising the best and safest practices.
Our Company is a commercial business operating in a competitive market. The pursuit of the highest quality of service to our customers is as essential to the long-term growth and survival of the business as cost control and optimum pricing.
To secure our success, Paint My Home is driven to execute each and every project ‘right first time’. To achieve this, we must designate the optimum management time and resources for setting up each project at your home, to ensure that delivery of the works creates the least possible impact and disruption, with no delays, effective communication and quality workmanship.
By using our knowledge gained through over 30 years of experience in property maintenance, design and refurbishment, we shall bring to any project; our commitment to an open and honest relationship which allows a clear two-way flow of information, ensuring you as the customer are satisfied and everyone is informed at all stage of the work; commitment to sharing ideas from other projects which we deem beneficial to work on your particular property; commitment to training our staff specific to the requirements of the specification, your property, required customer expectations and any particular needs, and; our commitment to implementing tailored customer care processes to enable delivery of the works in the most efficient and professional manner.
Quality Assurance System
In order to ensure that all work is carried out in a manner that provides the highest quality of service to our clients, the Company has put in to effect a Quality Management System. This complies with the requirements of ISO 9001:2015 and revolves around:
• Understanding and reacting to the needs and expectations of interested parties
• Leadership and commitment
• Planning – Risks and Opportunities
• Planning – Quality Objectives
• Operational Planning and Control
• Performance Evaluation
• Continuous Improvement
• Management Review
The Management consistently strives to understand current and future needs of our customers and to exceed their expectations. This is achieved by creating an internal culture in which all staff become completely familiar with and understand all procedures of the quality system relevant to their own work and ultimately become fully involved in achieving the organisation’s objectives.
For and on behalf of Paint My Home:-

Reviewed: 1st October 2020
To Review: 1st October 2021

Chief Executive, Craig Bell

CUSTOMER COMPLAINTS POLICY

Policy Statement

Paint My Home, as a subsidiary of Bell Group U.K., is fully committed to reducing complaints in a collaborative and professional manner, within an agreed timescale and to the customer’s full satisfaction, as one of the Company’s two principal Quality Objectives.
It is our Policy that
✓ All customer based issues shall be dealt with by a trained customer care administrator and/or Community Engagement Coordinator (CEC) to ensure the utmost satisfaction and equal care for all clients, customers and members of the public.
✓ The Company shall ensure our Complaints Procedure is well publicised and accessible to all.
✓ Complaints shall be dealt with in a full and fair way.
✓ Customers’ confidentially shall be respected when handling a complaint.
✓ Feedback shall be comprehensive and fully explained to the complainant.
✓ Target timescales shall be agreed with clients where possible for issue escalation and resolution, and ultimately staff shall adhere to our target of 10 working days for the full settlement of any arising complaint.
✓ Issue resolution outcomes shall be utilised for future training. Employees are encouraged to pass on any feedback on how we can improve our system
We operate a Management structure and Escalation Process for dealing with complaints, which comprises any issue being fully investigated and all relevant parties being interviewed and involved in the resolution. Appropriate corrective actions shall be implemented including; changes to procedures, introduction of new policies and bulletins, increased monitoring and reporting, tool-box-talks, external training courses, workshops with our management team as appropriate. Our Quality Manager carries out thorough analysis of the root cause for all complaints and reports figures monthly on complaints and corrective actions to the Board of Directors.
For any proposed contract to be undertaken, the hierarchy of persons responsible shall include:
• Customer Care administrator / Community Engagement Coordinator
• Bell Group’s Contract Manager / Branch Manager,
• Regional Director, Quality Manager, Health, Safety and Environmental Director as appropriate
All customers shall be provided with contact details for our team members prior to the commencement of work at your home, including office numbers, mobile numbers for key individuals and email.
For and on behalf of Bell Group UK: Chief Executive, Craig Bell
(including Paint My Home and all wholly owned subsidiaries)
Reviewed: 01/10/2020
Review Date: 01/10/2021

HEALTH AND SAFETY POLICY

Group Policy Statement

The Directors of Bell Group UK and our wholly owned subsidiaries, including Paint My Homes, recognise the importance of safe and healthy working practice and have compiled this Policy in compliance with Section 2(3) of the Health and Safety at Work Etc. Act 1974 and in line with the requirements of ISO 45001:2018. In furtherance of our duty, we will so far as is reasonably practicable, comply with the aforementioned Act, all relevant Statutory Instruments, Codes of Practice, other applicable legislation and other requirements i.e. from clients and the ISO standard, (legal and other) to ensure the safety, health and welfare of our employees and others affected by our operations.
This will be achieved by: –
• Meeting its responsibilities as an employer to do all that is reasonably practicable to prevent accidents, injuries and damage to health.
• Ensuring all employees play an active role in the health and safety of the company providing a commitment by consulting with them and providing them with adequate information, instruction, training and supervision (including participation) to enable them to understand their role and responsibilities within the company. Worker representatives attend all H&S improvement group meetings.
• Setting standards that comply with the relevant statutory requirements relating to health, safety and welfare with regards to the effect on employees, contractors, visitors and the public.
• Safeguard employees and others from foreseeable hazards, connected with work activities, processes and working systems.
• Ensuring risk assessments and safe methods of working for all workplace activities are established and providing suitable and sufficient control measures for hazardous activities that cannot be eliminated and making the results of these assessments known to employees.
• Providing suitable plant/machinery and equipment, ensuring working practice surrounding said items is safe and without unnecessary risk to health by, implementing and monitoring an effective programme of maintenance.
• Maintaining a safe working environment and safe access/egress from, Bell Group UK and Paint My Home premises and sites.
• Providing a safe system of work and robust management system (including continual improvement), considering health screening and providing suitable welfare facilities for all employees.
• Ensuring that contractors undertaking work for the company are informed of the relevant standards required and are monitored to ensure compliance without detracting from the contractors’ legal responsibilities to comply with statutory requirements.
• Provide adequate resources to comply with statutory requirements with regards to the health, safety and welfare of all those affected by its activities.
• Setting clear Occupational Health and Safety objectives which will be communicated to all workers.
• We ensure continuing improvements of the management system for health and safety and ensure that we engage with all workers in encouraging and enabling their inputs for improvements.
We need and want a competent team of workers that are individually and collectively capable of planning and managing work with wellbeing in mind and with the ability to look after themselves making sensible and proportional decisions to achieve this.

Every employee has a legal and moral duty to co-operate with the Directors of Bell Group UK and Paint My Homes, in meeting their statutory obligations.
Every employee of Paint My Home must take all due care to safeguard not only their own health and safety, but also that of other persons that may be affected by their acts or omissions while in the employment of Bell and PMH.
All employees are advised that it is their duty to use protection devices, personal protective equipment and follow written procedures provided, in the furtherance of safety, health and welfare, and avoid putting others at risk through their reckless actions or malicious intent. Any employee who fails to comply with safety provisions may have their contract of employment terminated.
This Policy will be regularly reviewed/monitored by Bell Group UK and amended as required, taking into consideration new legislation and improved/new working practices. These amendments will be brought to the attention of all Paint My Homes Employees.
Consultation on matters affecting health and safety will be undertaken with employees to ensure effective methods of working are developed, compatible with the provisions of this policy and the individual capabilities of employees. All operatives are provided with Bell Core Training on an annual basis which will include updates on legislation, good practice and amendments to any procedures and safe working procedures.
Adequate resources will be provided to ensure that suitable provision is made for the effective management of health and safety and to enable compliance with the requirements of legislation so far as is reasonably practicable.
Craig Bell / Chief Executive Officer is the senior person responsible for Health and Safety Management within the Bell Group supported by the board of directors.
For and on behalf of Bell Group U.K Limited, and all wholly owned subsidiaries,
including Paint My Home:-
Reviewed: 1st October 2020
To Review: 1st October 2021

Chief Executive, Craig Bell

ENVIRONMENTAL POLICY

Group Policy Statement
Introduction
In the pursuit of our business objectives, Bell Group UK and all wholly owned subsidiaries, including Paint My Home, are a major user of timber, solvent based coatings, motor vehicles and plant, which bring great benefits to modern society, but their resourcing and technologies have a detrimental effect on the environment. Paint My Home and Bell Group recognise that some solvent based fumes and CO2 emissions from engines are a contributor to global warming and likewise, the sourcing of sustainable timber is a vital component to combat the same. In particular, vehicle emissions have an adverse effect on air quality, with potential consequences for public health.
Our Company cares about the environment and we accept that we are part of a global community from which many benefits are derived, but also to which we owe great responsibility. As parent company to Paint My Home, Bell Group UK accepts responsibility on behalf of all subsidiaries, to mitigate the impact of our operations on the global community and the environment on which we depend. As such the Company has put in to effect an Environmental Management System which complies with ISO14001:2015 and considers all relevant legislation.
The Purpose of Our Environmental Management System is for Bell Group U.K. to;
• recognise that environmental protection is a strategic business issue and an integrated part of our corporate strategy in operating our company;
• recognise that a healthy natural environment is essential for sustainable development;
• be committed to the protection and enhancement of the environment when carrying out our own functions and duties;
• accept responsibility for complying with all relevant environmental legislation and requirements of the ISO 14001 standard;
• minimise the environmental effects of all Group activities;
• be committed to the recognised waste management practices of source reduction, reuse, recycling, resource recovery and environmentally safe residue disposal; and
• be committed to continual improvement of our environmental performance through implementation, monitoring and review of Environmental Targets, Company policies, sustainability objectives, programmes and services.
The principles that underlie the Policy statement are:-
• “prevention is better than cure” – it is always preferable to prevent an environmental problem emerging than trying to clean up afterwards;
• “the polluter pays” – the organisation or individuals responsible for environmental threat should bear the cost of cleaning up, or of prevention;
• “equal priority” – the protection of the environment ranks equally with other business activities such as Health and Safety, Quality, Customer Satisfaction and Financial Control;
• “resource efficiency” – activities will be conducted in ways which result in the most efficient use of natural resources; and
• “no harm” – this applies to our people and the environment

Environmental Policy Commitments
There are policies and benchmark standards actively pursued within our business involving the purchase of raw materials and the purchase and use of chemicals and vehicles. Our standard operating procedures are in consideration of our environment and include but are not limited to the following:
➢ We source people locally for our contract sites in consideration of required travel, shared transportation and reducing our carbon footprint.
➢ We commit to identify the main environmental aspects of Bell Group and our subsidiary activities and assess the significance of the environmental impacts arising from this, whilst considering the full life cycle perspective.
➢ We seek to reduce levels of consumption and waste in all materials we use through accurate planning and methodology. We strongly encourage recycling of waste / left-over materials where reasonably possible
➢ We work with all our suppliers and clients to ensure we are using items required for the successful delivery of our services, in consideration of our environment.
➢ We utilise energy saving technologies and adopt energy saving practices at our Branches and on site in order to minimise our consumption levels and carbon footprint.
➢ We collaborate with our suppliers to specify the most environmentally friendly materials as well as effective recycling and waste disposal methods
➢ Wherever possible we use equipment that reduces overall consumption.
➢ We operate a segregation of waste system at our Branches and on all sites to dispose of materials professionally according to type.
➢ The vehicles we use to facilitate the delivery of our services form a major part in our dedicated approach to working in consideration of environmentally ethical operations.
➢ We are committed to working towards a paperless environment, encouraging staff to use and view documents electronically.
➢ We work with a number of organisations through the recycling of printer cartridges, paper, paint tins, cardboard and paint surplus.
➢ We have implemented a UK wide policy and KPIs relating to the recycling of waste and ultimately reducing the effects on landfill sites.
➢ We maintain a Register of Environmental Aspects & Impacts, assessing the significance of impacts and implementing mitigation measures to minimise impacts.
➢ We will continue to produce an annual carbon footprint report outlining the sources and consumption levels of carbon producing activities.
➢ The continuous support and training we deliver to our people includes these visions and values.
For and on behalf of Bell Group U.K Limited, and all wholly owned subsidiaries,
including Paint My Home:-
Reviewed: 1st October 2020
To Review: 1st October 2021

Chief Executive, Craig Bell

QUALITY POLICY

Group Policy Statement
It is the policy and a principal business objective of Bell Group UK and all wholly owned subsidiaries, to provide the highest quality of service to clients and customers. Operating in a competitive market, the pursuit of optimum quality of service is as essential to the growth and long-term survival of the business as cost control.
To achieve this we;
• are driven to execute each and every project ‘right first time’, focusing on a zero defects regime
• designate the optimum management time and resources for planning and setting up each contract;
• invest in breeding, nurturing and training our own core of skilled operatives from apprenticeships to management through training and internal promotion
• promote opportunities for personal development and employee wellbeing
• ensure a true collaborative working ethos is ingrained at every level of the business
• Share our knowledge and expertise with all interested parties, gained through 30 years of maintenance repairs and painting contracts in occupied residential dwellings,
• utilise resources of our Supply Chain Partners
• develop the most efficient formula for methodology and delivery of the works, taking in to consideration all affecting factors to provide a best value service;
• ensure maximum collaboration with all interested parties, considering their needs and expectations.
• invest in optimum quality of preparation and workmanship, therefore increasing the lifecycle and sustainability of our product, which ensures our work improves the lives of our customers.
• Deploy expert supervisory staff and cherry pick the most suitable qualified skilled operatives to each and every project, ensuring all parties are trained in the requirements of our customers
• create an effective communication flow, which ensures the least possible impact, disruption and delays.
In order to ensure that all work is carried out in a manner which provides the highest quality of service to clients, the Company has put into effect a Quality Management System. This complies with the requirements of ISO 9001:2015. The MS Manual defines this system and the work procedures entailed.
Paint My Home Management consistently strives to understand current and future needs of our customers and to exceed customer expectation. This is achieved by creating an internal environment in which all staff are required to become completely familiar and understand all procedures of the quality system relevant to their own work and ultimately become fully involved in achieving the organisations objectives. We believe that the responsibility in delivering a first class service lies with all members of our team; starting with our operatives and involving the site foreman, contract management, administration and surveying staff.
The management has established a structure that encourages and promotes continual improvement of the QMS through the use of quality objectives, audit results, analysis of data, corrective and preventative actions and management review. This policy statement has immediate effect.
For and on behalf of Bell Group U.K Limited, and all wholly owned subsidiaries,
including Paint My Home:-
Reviewed: 1st October 2020
To Review: 1st October 2021

Chief Executive, Craig Bell

ANTI-BRIBERY AND CORRUPTION POLICY

INTRODUCTION
Bribery
Bribery is the offering, promising, giving, solicitation or the receipt or agreement to receive any financial or other advantage, or any other inducement from any person or company, (wherever they are situated and whether they are a public official or body, a private person or company) by an individual employee, agent or other person or body acting on another’s behalf.
Corruption
Corruption is the abuse of entrusted power for a private gain.
POLICY STATEMENT
The purpose of this document is to set out the Policy of Paint My Home (as a wholly owned subsidiary of Bell Group UK), on the giving and receiving of gifts, hospitality and entertainment, and our responsibilities under this Policy. It aims to ensure transparency, provide clarity on acceptable behaviour and comply with the UK Bribery Act 2010.
As a general policy, Paint My Home does not believe that giving and receiving gifts is appropriate to the efficient conduct of our organisation. There are, however, limited exceptions to this policy, since the Company recognises that the giving and accepting of gifts, entertainment and hospitality can sometimes be part of building normal business relationships. This practice can vary significantly between the various geographical locations in which Paint My Home does business. However, regardless of local laws and customs, some gifts and hospitality can lead to the suggestion that an improper influence has been asserted, either on or by Paint My Home or Bell Group, or that a conflict of interest has arisen. In some instances, the giving and/or receiving of gifts and entertainment can be interpreted as a bribe, which is unlawful and which can lead to criminal prosecution for those individuals involved as well as the company. Bribery is illegal in the UK.
Bell Group UK, and our subsidiary businesses including Paint My Home, value our reputation for ethical behaviour and for financial probity and reliability. We recognise that over and above the commission of any crime, any involvement in bribery will also reflect adversely on our image and reputation. The aim of this Policy is therefore to ensure that the highest standards of integrity are maintained and that it can never be suggested that there was an improper motive behind the offer or acceptance of the gift or hospitality, of unduly influencing the recipient, or on the part of the recipient in accepting it.
Our aim is to limit the Company’s exposure to bribery and corruption by:
• Setting out a clear Anti-Bribery & Corruption policy;
• Training employees so that they can recognise and avoid the use of bribery or corruption by themselves and others;
• Encouraging our employees to be vigilant and to report any suspicion of bribery or corruption, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately;
• Rigorously investigating instances of alleged bribery or corruption and assisting the police and other appropriate authorities in any resultant prosecution;
• Taking firm and vigorous action against any individual(s) involved in bribery.
Application of this Policy
This Policy applies equally to employees of Paint My Home, and parent company Bell Group UK, and individuals who may not be directly employed by the Company, but who are carrying out duties on behalf of, or for the benefit of Paint My Home.
Paint My Home, absolutely forbids corruption and the paying or receipt of bribes for any purpose.
The prevention, detection and reporting of bribery or corruption is the responsibility of all persons within or associated with Paint My Home and Bell Group UK. Reports can be made confidentially to:
Paramjit Barry,
Human Resources Manager for Paint My Home Bell Group UK Head Office
012367 66878
p.barry@bellgroup.co.uk
For and on behalf of Bell Group U.K Limited,
and all wholly-owned subsidiaries, including Paint My Home:-
Chief Executive, Craig BellReviewed: 1st October 2020
To Review: 1st October 2021

SAFEGUARDING VULNERABLE ADULTS AND CHILDREN

This document is available in large print, Welsh, audio and Braille on request.
Please call 01236 766878 or email HR@bellgroup.co.uk
POLICY STATEMENT
As an all-encompassing property maintenance contractor, Paint My Home’s principal activities involve working in and around domestic properties. All of our skilled tradesmen and women will come in to contact with members of the public almost on a daily basis.
It is therefore inevitable that within our workplace, safeguarding the welfare of all customers including children, young people and vulnerable adults plays a vital role in our daily activities and all Paint My Home staff must be aware of their responsibilities in this regard. Paint My Home, and Bell Group UK as our parent company, aim to assure the safe and secure service provision for all our customers, including children, young people and vulnerable adults, across all Company activities, through effective management systems, training, inspection and regulation.
Paint My Home is committed to the following principles in all aspects of our work:
✓ Empowerment – putting people first and helping those who lack mental or physical capacity to feel involved and informed about our work activities
✓ Partnership – sharing the right information in the right way with our customers and providing adequate resources to achieve an optimum service
✓ Protection – ensuring we implement adequate protective procedures in and around the work areas to ensure the safety and protection of customers and especially highlighting needs of vulnerable residents or members of the public
✓ Support – supporting customers and residents in the communities where we work through social value, community events, sponsorships, employment opportunities and upskilling initiatives, so they have the opportunity to take action and take control of their circumstances
✓ Prevention – responding quickly to suspected cases of abuse or suspicious circumstances
✓ Proportionality – making sure what we do is appropriate to the situation and for the individual
✓ Accountability – making sure all parties to the project have clear roles and responsibilities
Safeguarding is a general term used to describe how we protect adults and children from abuse or neglect. Within the realm of Bell Group and Paint My Home’s activities, Safeguarding is about protecting all customers affected by our workplace activities and in particular making certain we provide a tailored customer care service to those in vulnerable circumstances. Our Safeguarding procedure also covers for reporting and taking action where we come across people within our daily jobs whom we suspect may be at risk of abuse or neglect due to the actions (or lack of action) of another person. In these cases, it is vital that our staff work together with our clients and relative authorities to ensure any suspected matters are dealt with swiftly and effectively. This topic is also covered within our Policy on Anti-Trafficking and Modern Slavery.

Paint My Home takes full responsibility to ensure that the workplace activities do not have a negative impact on the safety and welfare of others. To assist with attaining the above commitments, we adhere to standard procedures through the mobilisation of any contract:
• Liaise with our management to gather vital information relating to customer profiles and special considerations.
• Inherently, from this information, our Project Manager shall formulate a customer liaison plan and cherry-pick the most suitable individuals for each project.
A stringent selection process shall be followed to engage individuals, specific to the work activities, based on: previous experience of similar work, skill base, qualifications and training, length of service and DBS checks where required. Thus, we ascertain the comprehensive training of site teams, with the secure knowledge that individuals are highly experienced in carrying out their activities in a safe manner.
• As a Company, we shall endeavour to engage 100% of directly employed local labour where reasonably possible. Consequently, we can rely on individuals being familiar with the local area and to identify and act upon safeguarding concerns which may arise.
• We carry out comprehensive induction training with all team members specific to the project in hand, covering the Construction Phase Plan, PPE, welfare of others and service delivery relevant to the customer.
As a Company, we commit to carrying out effective training with our employees on Code of Conduct, Respect for People, Customer Care and Safeguarding with all our employees on a continuous basis. We shall continue to work with our clients and external training providers in the most collaborative manner to focus on topics which will not only improve our own Safeguarding procedures internally, but as an industry leader, we aim to mould our clients’ expectations and proactively push for positive change in the Customer Care approach adopted by all Companies within the property maintenance industry.
For and on behalf of Bell Group U.K Limited, and all wholly owned subsidiaries,
including Paint My Home:-
Chief Executive, Craig Bell
Reviewed: 1st October 2020
To Review: 1st October 2021

MODERN SLAVERY AND HUMAN TRAFFICKING POLICY

Policy Statement
Modern Slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
Within Bell Group UK Limited (and all associated subsidiary companies, including Paint My Home) we have a zero tolerance approach to modern slavery. We are committed to driving out acts of modern day slavery and human trafficking by acting ethically and with integrity in all our business dealings and relationships. We endeavour to implement and enforce effective systems and controls to ensure modern slavery is not taking place in any activity related to our business or throughout our supply chain, including subcontractors and partners. The company will not support or deal with any business or individual knowingly involved in slavery or human trafficking.
We use the following framework to focus on six areas of our business, which ensures our efforts are maximised and appropriate in line with our business activities:
1. Structure, business activities and our supply chains
2. Policies in relation to slavery and human trafficking
3. Identification of risks together with steps taken to prevent and manage that risk
4. Due diligence processes in relation to slavery and human trafficking within our business and supply chains
5. Effectiveness in ensuring that slavery and human trafficking is not taking place in our business or supply chains, measured against appropriate KPIs, and
6. Training and capacity building about slavery and human trafficking
We acknowledge our responsibility to the Modern Slavery Act 2015 and will ensure transparency within our Organisation. This shall include the communication of our Group’s Policy and implementation of our anti-trafficking procedure throughout our full supply chain to the best of our ability. The full supply chain refers to both suppliers of goods and services to the organisation as well as our own employees and any other stakeholders of Paint My Home and Bell Group UK Limited. We expect the same high standards from all of our Contractors, suppliers and other business partners, and as part of our contracting process, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
The Company pledges to ensure adequate levels of management control required for these sources and will continually monitor this. The Board of Directors and senior management shall take responsibility for implementing this policy and its objectives and shall provide adequate resources to monitor our risk and control measures through various channels to ensure that slavery and human trafficking is not taking place within the organisation or within our supply chains. Our monitoring methods shall include, but are not limited to;
o Training of site staff to spread awareness of this issue
o Making our Policy available to all employees,
o Close monitoring of branch operations by Senior managers,
o Consideration of feedback from contracts staff and site operatives,
o Through one-to-one career assessments with staff
o Through ensuring we continue to utilise the resources of Constructionline in engaging suppliers
o Through liaising with Constructionline to set up ‘meet the contractor’ events UK-wide
o Through attending conferences and events in relation to this topic to make certain that we keep up to date with current legislation and implement adequate procedures.
The Board of Directors reviews this policy and our monitoring procedures annually.
For and on behalf of Bell Group U.K Limited, and all wholly owned subsidiaries,
including Paint My Home:-
Chief Executive, Craig Bell
Reviewed: 1st October 2020
To Review: 1st October 2021

SUBSTANCE MISUSE POLICY

POLICY STATEMENT
It is the policy of Bell Group UK and all wholly owned subsidiaries, including Paint My Home, to safeguard, so far as is reasonably practicable, the Health, Safety and Welfare of everyone on site and working within our business and customer premises.
This requires therefore a zero tolerance policy on the misuse of alcohol, drugs and solvents by all employees. The Company believes that the creation of a Health and Safety culture, based on welfare principles, is only achievable by total commitment, adequate resources and complete cooperation between all parties concerned.
The Company has no desire to interfere with any employee’s personal life or to reduce any social activities carried out in a reasonable manner. Employees should however understand that the psychological and physical effects of alcohol and other substances which affect behaviour and judgement could inadvertently be brought in to the workplace.
This Policy also aims to highlight that the Company will provide confidential advice and a provision for external counselling for anyone who thinks they require help with a drug or alcohol problem.
Where a worker is found suspected to be under the influence of alcohol, drugs or solvents, the Company may take steps to protect the safety and wellbeing of that person and all those working within the workplace vicinity. Such action will be based on the considered safety risks of those affected, as well as considering our obligation in maintaining the professional reputation of Paint My Home, which may involve disciplinary proceedings.
Scope
The Policy covers misuse of over-the-counter and prescription medication as well as illegal drugs.
The Policy covers all workers and includes the requirement to be in a fit condition whilst engaged in Company operations. For the purpose of this Policy, the word ‘worker’ shall be used to describe all employees, trainees, apprentices, agency workers and subcontractors.
For and on behalf of Bell Group U.K Limited, and all wholly owned subsidiaries,
including Paint My Home:-
Chief Executive, Craig Bell
Reviewed: 1st October 2020
To Review: 1st October 2021

ANTI HARRASSMENT AND BULLYING POLICY

POLICY STATEMENT
Bell Group UK and all our subsidiaries, including Paint My Home, welcome diversity and believe that each member of staff has a right to work in an environment that encourages harmonious relationships. We are committed to preventing harassment and bullying and it is the responsibility of all managers to ensure that each member of staff is aware of and understands our procedures relating to harassment and bulling.
Every manager should aim to promote a working environment in which harassment and bullying cannot flourish. They should take immediate action if harassment and/or bullying is suspected or identified, whether or not a complaint has been made. Allegations of harassment and bullying received either formally or informally, must be taken seriously and dealt with promptly and sensitively.
In addition to our commitment to equality and diversity, we are fully aware of our legal obligation to ensure that harassment on the grounds of an individual’s race, age, gender, disability, sexual orientation, religion or belief, gender reassignment, pregnancy or maternity, marital or civil partnership status or harassment on any other grounds, does not take place at work, on site, on any other location associated with our organisation. We have a duty of care towards each member of staff and any other persons associated with our company (e.g. suppliers, clients, residents, customers, visitors, consultants and subcontractors) under the Health and Safety Act 1974 (and subsequent amendments).
Each member of staff is personally liable under this legislation; allegations of harassment and/or bullying will be treated seriously and may result in disciplinary action being taken against the perpetrator. We will ensure that each member of staff raising a concern is not victimised as a result. We will also treat any allegations proven to be malicious extremely seriously; these allegations are also likely to be the subject of disciplinary action should they be proven. The overriding principles in dealing with allegations or concerns of harassment are that they must be taken seriously, considered carefully and addressed speedily and where possible, in confidence.
For and on behalf of Bell Group U.K Limited, and all wholly owned subsidiaries,
including Paint My Home:-
Chief Executive, Craig Bell
Reviewed: 1st October 2020
To Review: 1st October 2021