About Us
We operate in the professional service community. In the accountancy and finance market we work with all the significant accounting practices, private equity, corporate finance and venture capital boutiques. Whether you are a prospective client or a candidate, our aim is to be the consultancy with whom you can discuss your requirements in order to achieve either your corporate or personal objectives.
“To deliver outstanding recruitment services – from both the clients’ and candidates’ perspective.”
- We treat clients and candidates the way we would want to be treated.
- We do what is right, we never let a fee get in the way.
- We give clients a good fair deal.
- We do not maximise short-term profit at the expense of building long-term relationships.
- We always look for ways for our clients and candidates to do business.
- We communicate often with clients and candidates.
- We do not forget to say ‘thank you’.
- We go the extra mile in everything we do.
Meet the Team
The people you’ll meet at Adlestrop are talented experts who love their work. Some are young (ish). Some are older (and wiser!). But each of them knows their stuff and we all work hard for you.
Our people do everything they can to be available when you need them. They’re only a quick call away and are always happy to offer advice, support and handy hints in addition to finding you a great career move or a new team member. And because it’s always nice to put a face to a name, here is our team.
Charles
Magill
Director
Accountancy & Finance
[Photo]
[Link to Bio Page]
Natalie
Price
Personal Assistant & Office Manager
[Photo]
[Link to Bio Page]
Jack
McCaughtrie
Consultant
Marketing & Communication
[Photo]
[Link to Bio Page]
Karen
Smithies
Research Associate
Karen
Smithies
Research Associate
Blog
[Listing of Blog articles – review and categorise]
Join Us
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Privacy Policy
INTRODUCTION
This Privacy Policy explains what we do with your personal data, whether we are in the process of helping you find a job, continuing our relationship with you once we have found you a role, providing you with a service, receiving a service from you, using your data to ask for your assistance in relation to one of our Candidates, or you are visiting our website.
It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.
This Privacy Policy applies to the personal data of our Website Users, Candidates, Clients, Suppliers, and other people whom we may contact in order to find out more about our Candidates or whom they indicate is an emergency contact. It also applies to the emergency contacts of our Staff. To be clear, if you are a member of Adlestrop Consulting’s Staff, you should refer to the Adlestrop Consulting’s Staff Privacy Policy which is available on our internal system.
It is important to point out that we may amend this Privacy Policy from time to time. Please just visit this page if you want to stay up to date, as we will post any changes here.
If you are dissatisfied with any aspect of our Privacy Policy, you may have legal rights and, where relevant, we have described these as well.
What kind of personal data do we collect?
CANDIDATE DATA: In order to provide the best possible employment opportunities that are tailored to you, we need to process certain information about you. We only ask for details that will genuinely help us to help you, such as your name, contact details, education details, employment history, emergency contacts, immigration status, financial information (where we need to carry out financial background checks), and social security number (and of course you may choose to share other relevant information with us). Where appropriate and in accordance with local laws and requirements, we may also collect information related to your health, diversity information or details of any criminal convictions.
To the extent that you access our website we will also collect certain data from you.
CLIENT DATA: If you are an Adlestrop Consulting customer, we need to collect and use information about you, or individuals at your organisation, in the course of providing you services such as: (i) finding Candidates who are the right fit for you or your organisation; (ii) working with you on a retained headhunting exercise; (iii) sharing market insights and observations with you.
SUPPLIER DATA: We need a small amount of information from our Suppliers to ensure that things run smoothly. We need contact details of relevant individuals at your organisation so that we can communicate with you. We also need other information such as your bank details so that we can pay for the services you provide (if this is part of the contractual arrangements between us).
To the extent that you access our website we will also collect certain data from you.
PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS: In order to provide Candidates with suitable employment opportunities safely and securely and to provide for every eventuality for them and our Staff, we need some basic background information. We only ask for very basic contact details, so that we can get in touch with you either for a reference or because you’ve been listed as an emergency contact for one of our Candidates or Staff members.
A number of elements of the personal data we collect from you are required to enable us to fulfil our contractual duties to you or to others. Where appropriate, some, for example Candidates’ social security number and, religious affiliation, are required by statute or other laws. Other items may simply be needed to ensure that our relationship can run smoothly.
Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfil our contractual requirements or, in extreme cases, may not be able to continue with our relationship.
How do we collect your personal data?
CANDIDATE DATA: There are two main ways in which we collect your personal data:
1. Directly from you; and
2. From third parties.
To the extent that you access our website or read or click on an email from us, we may also collect certain data automatically or through you providing it to us.
CLIENT DATA: There are two main ways in which we collect your personal data:
1 Directly from you; and
2 From third parties (e.g. our Candidates) and other limited sources (e.g. online and offline media).
To the extent that you access our website or read or click on an email from us, we may also collect certain data automatically or through you providing it to us.
SUPPLIER DATA: We collect your personal data during the course of our work with you.
To the extent that you access our website or read or click on an email from us, we may also collect certain data automatically or through you providing it to us.
PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS: We collect your contact details only where a Candidate or a member of our Staff puts you down as their emergency contact or where a Candidate gives them to us in order for you to serve as a referee.
How do we use your personal data?
CANDIDATE DATA: The main reason for using your personal details is to help you find employment or other work roles that might be suitable for you. The more information we have about you, your skillset and your ambitions, the more bespoke we can make our service. Where appropriate and in accordance with local laws and requirements, we may also use your personal data for things like marketing and diversity monitoring. Where appropriate, we will seek your consent to undertake some of these activities.
CLIENT DATA: The main reason for using information about Clients is to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly. This may involve: (i) identifying Candidates who we think will be the right fit for you or your organisation; (ii) working with on a headhunting exercise; (iii) sharing market insights and observations. The more information we have, the more bespoke we can make our service.
SUPPLIER DATA:The main reasons for using your personal data are to ensure that the contractual arrangements between us can properly be implemented so that the relationship can run smoothly, and to comply with legal requirements.
PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS: We use referees’ personal data to help our Candidates to find employment which is suited to them. If we are able to verify their details and qualifications, we can make sure that they are well matched with prospective employers. We may also use referees’ personal data to contact them in relation to recruitment activities that may be of interest to them. We use the personal details of a Candidates or Staff member’s emergency contacts in the case of an accident or emergency affecting that Candidates or member of Staff .
Please note that communications to and from Adlestrop Consulting’s Staff including emails may be reviewed as part of internal or external investigations or litigation.
Who do we share your personal data with?
CANDIDATE DATA: Primarily we will share your information with prospective employers to increase your chances of securing the job you want but will not share with any other party without your expressed consent.
CLIENT DATA: We will share your data primarily to ensure that we provide you with a suitable pool of Candidates.
SUPPLIER DATA: Unless you specify otherwise, we may share your information with any of our associated third parties such as our service providers and organisations to whom we provide services.
PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND STAFF, SUCH AS REFEREES AND EMERGENCY CONTACTS: Unless you specify otherwise, we may share your information with any of our associated third parties such as our service providers and organisations to whom we provide services.
WEBSITE USERS: Unless you specify otherwise, we may share your information with providers of web analytics services, marketing automation platforms and social media services to make sure any advertising you receive is targeted to you.
How do we safeguard your personal data?
We care about protecting your information. That’s why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your personal data.
How long do we keep your personal data for?
If we have not had meaningful contact with you (or, where appropriate, the company you are working for or with) for a period of two years, we will Delete your personal data from our systems unless we believe in good faith that the law or other regulation requires us to preserve it (for example, because of our obligations to tax authorities or in connection with any anticipated litigation).
How can you access, amend or take back the personal data that you have given to us?
Even if we already hold your personal data, you still have various rights in relation to it. To get in touch about these, please contact us. We will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
Right to object: If we are using your data because we deem it necessary for our legitimate interests to do so, and you do not agree, you have the right to object. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases). Generally, we will only disagree with you if certain limited conditions apply.
Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, for profiling your suitability for certain roles), or consent to market to you, you may withdraw your consent at any time.
Data Subject Access Requests (DSAR): Just so it’s clear, you have the right to ask us to confirm what information we hold about you at any time, and you may ask us to modify, update or Delete such information. At this point we may comply with your request or, additionally do one of the following:
– we may ask you to verify your identity, or ask for more information about your request; and
– where we are legally permitted to do so, we may decline your request, but we will explain why if we do so.
Right to erasure: In certain situations (for example, where we have processed your data unlawfully), you have the right to request us to “erase” your personal data. We will respond to your request within 30 days (although we may be allowed to extend this period in certain cases) and will only disagree with you if certain limited conditions apply. If we do agree to your request, we will Delete your data but will generally assume that you would prefer us to keep a note of your name on our register of individuals who would prefer not to be contacted. That way, we will minimise the chances of you being contacted in the future where your data are collected in unconnected circumstances. If you would prefer us not to do this, you are free to say so.
Right of data portability: If you wish, you have the right to transfer your data from us to another data controller. We will help with this – either by directly transferring your data for you, or by providing you with a copy in a commonly used machine-readable format.
Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority, details of which can be found here.
If your interests or requirements change, you can unsubscribe from part or all of our marketing content (for example job role emails or Adlestrop newsletters) by clicking the unsubscribe link in the email.
How do we store and transfer your data internationally?
Adlestrop use third party system which may mean we have to transfer or store your data internationally.
Who is responsible for processing your personal data on the Adlestrop website?
Adlestrop controls the processing of personal data on its website(s).
Corporate Social Responsibility Policy
At Adlestrop Consulting Ltd we recognise our responsibility to contribute positively to society and the environment in which we operate. Our commitment to Corporate Social Responsibility (CSR) is integral to our business philosophy and guides our decisions and actions.
1. Environmental Sustainability
We are dedicated to minimising our environmental footprint by:
Reducing energy consumption and promoting energy efficiency practices.
Minimising waste generation and promoting recycling initiatives.
Using environmentally friendly materials and technologies wherever feasible.
Complying with all relevant environmental laws and regulations.
2. Ethical Business Practices
We uphold the highest standards of integrity and ethics in all our business dealings by:
Conducting business with honesty, transparency, and fairness.
Respecting the rights and dignity of all individuals, including employees, customers, suppliers, and communities.
Zero tolerance for corruption, bribery, and unethical behaviour.
Ensuring compliance with all applicable laws and regulations related to our business operations.
3. Community Engagement
We are committed to being active and responsible members of the communities in which we operate by:
Supporting local community initiatives and charitable organisations through donations, volunteer work, and partnerships.
Engaging with stakeholders to understand their needs and concerns and working collaboratively to address them.
Providing opportunities for employee involvement in community service activities.
4. Employee Well-being
We prioritise the well-being and development of our employees by:
Providing a safe and healthy work environment free from discrimination, harassment, and any form of unfair treatment.
Offering competitive compensation, benefits, and opportunities for professional growth and advancement.
Promoting a culture of diversity, inclusion, and respect, where all employees feel valued and empowered.
Encouraging work-life balance and supporting employee wellness initiatives.
5. Supplier Relations
We seek to build strong and mutually beneficial relationships with our suppliers by:
Selecting suppliers who share our commitment to ethical and sustainable practices.
Ensuring fair and transparent procurement processes.
Providing support and guidance to suppliers to help them improve their sustainability performance.
6. Continuous Improvement
We are committed to continuously improving our CSR performance by:
Setting measurable goals and targets to track our progress.
Regularly assessing and reviewing our CSR initiatives and practices.
Soliciting feedback from stakeholders and incorporating their input into our decision-making processes.
Conclusion
At Adlestrop Consulting Ltd, we believe that integrating CSR into our business operations is not only the right thing to do but also essential for long-term success and sustainability. We are committed to upholding these principles and making a positive impact on society and the environment.
Anti-Slavery and Human Trafficking Policy
1. POLICY STATEMENT
1.1 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. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
1.2 We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, 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.
1.3 This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
1.4 This policy does not form part of any employee’s contract of employment and we may amend it at any time.
2. RESPONSIBILITY FOR THE POLICY
2.1 The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
2.2 The Compliance Manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
2.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
2.4 You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the compliance manager.
3. COMPLIANCE WITH THE POLICY
3.1 You must ensure that you read, understand and comply with this policy.
3.2 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
3.3 You must notify the compliance manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
3.4 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
3.5 If you believe or suspect a breach of this policy has occurred or that it may occur you must your Director as soon as possible. You should note that where appropriate, and with the welfare and safety of local workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains.
3.6 If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your Director.
3.7 We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the compliance manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in Company handbook.
4. COMMUNICATION AND AWARENESS OF THIS POLICY
4.1 Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
4.2 Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
5. BREACHES OF THIS POLICY
5.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
5.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
Anti-Slavery and Human Trafficking Policy
1. POLICY STATEMENT
1.1 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. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
1.2 We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, 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.
1.3 This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
1.4 This policy does not form part of any employee’s contract of employment and we may amend it at any time.
2. RESPONSIBILITY FOR THE POLICY
2.1 The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
2.2 The Compliance Manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
2.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
2.4 You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the compliance manager.
3. COMPLIANCE WITH THE POLICY
3.1 You must ensure that you read, understand and comply with this policy.
3.2 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
3.3 You must notify the compliance manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
3.4 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
3.5 If you believe or suspect a breach of this policy has occurred or that it may occur you must your Director as soon as possible. You should note that where appropriate, and with the welfare and safety of local workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains.
3.6 If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your Director.
3.7 We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the compliance manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in Company handbook.
4. COMMUNICATION AND AWARENESS OF THIS POLICY
4.1 Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
4.2 Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
5. BREACHES OF THIS POLICY
5.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
5.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
Equality and Diversity Policy
Introduction
Adlestrop Consulting as an employer recognises that everyone should have an equal chance to live, learn and work free from discrimination, harassment, victimisation and prejudice and is committed to delivering a high standard of client care and ensuring all its clients receive quality services to meet their needs.
Adlestrop Consulting recognise the importance or social and financial inclusion and that in addition to the protected characteristics, our clients may face social and financial advantage.
This policy sets out how Adlestrop Consulting are committed to incorporating the twin key principles of equality of opportunity and respect for diversity throughout its business.
Policy Statement
- We believe that equality and diversity are at the heart of everything we do.
- We are committed to the principle that all clients have the right to the same high standards of provision of services.
- We are committed to ensuring that all employees are treated with dignity and respect.
- We are committed to equality and diversity and recognise the nine protected characteristics as defined by the Equality Act 2010.
- We will make sure that the policy complies with all legal, statutory and regulatory requirements.
- We firmly believe that no one we employ should have to suffer unfair or unequal treatment from other employees, or from bodies or individuals with whom Adlestrop Consulting work with or provide services to.
Legislative and Regulatory Context
Adlestrop Consulting are committed to meeting the duties of the Equality Act 2010 which effectively replaced / consolidated previous equality legislation.
The Equality Act protects people sharing ‘protected characteristics’ of – age, disability, gender re-assignment, marriage and civil partnerships, pregnancy and maternity, race, religion or belief, sex and sexual orientation from discrimination.
We are committed to meeting the duties under the Modern Slavery Act 2015 to ensure that slavery and human trafficking are note taking place:
- Anywhere in our supply chains
- In any part of our business
Policy Definitions
Associative Discrimination – this is direct discrimination against someone because they associate with another person who possesses a protected characteristic i.e. an employee is passed over for promotion because they disclose they have a disabled family member and the manager assumes they not concentrate on their job because of their caring responsibilities.
Equality – Equality between individuals, where everyone has the same opportunities. No-one should be discriminated against because of their Protected Characteristics.
Diversity – Valuing the fact that individuals are different. Recognising that people with different backgrounds, skills and attitudes bring fresh ideas and opinions.
Direct Discrimination – This occurs when someone is treated less favourably than another person because of a protected characteristic they have or are thought to have (see Perceptive Discrimination), or because they associate with someone who has a protected characteristic (see Associative Discrimination).
Indirect Discrimination – When a condition or practice is put in place that disadvantages a person or group of people with protected characteristics, compared with others in the same group i.e. a change in working practices imposing a requirement that all employees should work on Saturday, may indirectly discriminate against an employee for whom Saturday is a religious day when work is not permitted.
Harassment – Unwanted behaviour that violates a person’s dignity or creates a degrading, humiliating, hostile, intimidating or offensive home/working environment.
Perceptive Discrimination – This is direct discrimination against an individual because others think they possess a particular characteristic i.e. A 40 year old employee who could pass for 25 is not promoted to a senior position because the recruiting manager thinks they look too young.
Positive Action – in some circumstances it may be appropriate (and legal) to take action to improve the opportunity someone with a protected characteristic has, to access a service or employment opportunity i.e. advertising a job vacancy in a specialist publication, such as ‘PosAbility’, as well as in the general press, increasing the likelihood of a person with a disability becoming aware of it.
Protected Characteristics –the Equality Act 2010 covers the same groups that were protected by earlier equality laws and extends protections to characteristics that were not previously covered. Protected Characteristics are: Age, Disability, Gender Reassignment, Marriage and Civil Partnership, Pregnancy and Maternity, Race, Religion or Belief, Sex and Sexual Orientation.
Third Party Harassment – The Equality Act makes employees potentially liable for harassment of their employees by people (third parties) who are not employees of the company, such as customers or clients, subject to certain conditions.
Victimisation – Less favourable treatment of a person because they have been involved in or brought, legal proceedings against individuals or organisations, or because they are suspected of doing so. This does not apply where the claims have been maliciously made or are proven to be untrue.
Prejudice – is when someone forms an opinion about something or somebody without knowing the full facts.
Modern Slavery – is a term used to encapsulate both offences in the Modern Slavery Act 2015, slavery, servitude and forced or compulsory labour, and human trafficking.
Slavery – slavery is defined as behaviour on the part of an offender as if he/she had a right to legal ownership over a person, which deprives the victim of their freedom.
Servitude – is the obligation to provide services that is imposed by the use of coercion and includes the obligation for the individual to live on another person’s property and the impossibility of changing his or her condition.
Forced or compulsory labour – is defined as all work or service which is exacted from any person under the menace of any penalty and for which the said person has not offered him/ herself voluntarily.
Human Trafficking – requires that a person arranges or facilitates the travel of another person with a view to that person being exploited.
This policy covers all aspects of providing services, employment and other areas of work.
Investigation under this policy may result in legal action against an individual. It may result in the company disciplinary procedures being followed where staff may be involved.
Our aim is that our directors, staff and contractors reflect the communities in which we work.
We have created our Equality and Diversity Policy and the measures to put it into place, on the basis of advice from the relevant organisations, reflecting best practice.
As a provider of services and as an employer we will ensure that:
- We will aim to eliminate discrimination and make sure we treat everyone fairly, with dignity and respect.
- We do not treat anyone receiving our services, or working for us less favourably than others and will consider appropriate positive action where legal.
- We review our policies and practices regularly and maintain up to date information on our employees and applicants for services or jobs to ensure that this policy is operating effectively.
- Staff are aware of current legislation and good practice and reflect our commitment to equal opportunities.
- All contractors, consultants and other agencies we work with meet the objectives of this policy.
- We will take effective action to tackle all forms of victimisation and harassment and we will always place the victim at the centre of what we do.
As a service provider we will:
- Seek to understand who our clients are and provide a range of services for people in the communities in which we work.
- Actively seek the views of clients and potential clients when planning, reviewing or making significant changes to our services, ensuring that our services are accessible, relevant and of use to our clients.
- Provide clear and meaningful information in ways which are accessible and which meet the diverse needs of our clients.
- Investigate promptly any complaint and take immediate action where there is evidence of direct or indirect discrimination.
- Monitor and evaluate the services we provide to ensure they do not discriminate or exclude individuals or people from different groups.
As an employer we will:
- Seek to establish a workforce that reflects the local population in which we work. We will adopt recruitment, support and retention practices (for example flexible working procedures) to support this aim.
- Assist staff to realise their potential ensuring fair consideration of their training and career development needs are identified through the Personal Progress Review.
- Provide a safe, supportive and accessible working environment.
- Monitor our employment policies and practices to ensure they are fair and demonstrate our commitment to diversity.
- Ensure that staff understand how valuing diversity can improve our ability to deliver better quality services and so reduce inequality.
- Ensure all staff are aware of the policy through induction training. Further updates or training specific to an employee’s role and service area will be undertaken when required, focussing on legal and good practice.
In working with others, we will:
- Promote, share information, experiences and examples of good practice of equality and diversity through links with other organisations.
- Ensure that equality and diversity is embedded throughout our procurement activity, and that slavery and human trafficking are not taking place within our supply chains.
Implementation
Directors have the overall responsibility for this policy and its implementation.
All employees and directors will be trained and provided with guidance on this policy to ensure that they clearly understand their position in law, and the implications for them.
Equality Impact Assessment
Adlestrop Consulting will ensure that our services reflect the clients that we work with and are in line with this policy.
An Equality Impact Assessment has been undertaken in respect of this policy to understand the impact it may have on groups or individuals.
The company is committed to equal opportunities and as such all clients will be dealt with fairly, consistently, and no one will be discriminated against.
Performance Measurement and Targets
We will seek to ensure that our commitment to equality and diversity and the elements of this policy are implemented through:
Using Equality Impact Assessments, analysis of equality data and benchmarking, opportunities to inform and influence policy and service delivery.
Monitoring our key services by equality group/ protected characteristics.
Involving customers and partners to shape our future activities.
Using our learning and development programmes to deliver consistent messages relating to this policy.
Participating in forums to help improve our understanding of the issues and to receive and share best practice.
Monitoring and Review
Directors and staff are ultimately responsible for this policy. Together we will monitor the effectiveness and implementation of the policy and recommend changes to improve service delivery where appropriate.
This policy and any associated procedures will be reviewed every 3 years to ensure its continued relevance, adequacy and effectiveness or as required by the introduction of new legislation or regulation.
Anti-Corruption and Bribery Policy
Policy statement
It is the policy of Adlestrop Consulting Ltd (the Company) to conduct business in an honest and ethical manner. As part of that, the Company takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships, wherever it operates, and implementing and enforcing effective systems to counter bribery.
Purpose
The Company will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which it conducts business, including, in the UK, the Bribery Act 2010 (the Act), which applies to conduct both in the UK and abroad.
Scope and applicability
This policy applies to all individuals working for or on behalf of the Company at all levels and grades, whether permanent, fixed-term or temporary, and wherever located, including consultants, contractors, seconded staff, casual staff, agency staff, volunteers, agents, sponsors and any other person who performs services for or on behalf of the Company, (collectively referred to as Workers in this policy).
In this policy, Third Party means any individual or organisation that Workers come into contact with during the course of work and the running of the Company’s business, and includes actual and potential clients, intermediaries, referrers of work, suppliers, distributors, business contacts, agents, advisers, government and public bodies (including their advisers, representatives and officials), politicians and political parties.
What is bribery?
A bribe is an inducement or reward offered, promised or provided in order to improperly gain any commercial, contractual, regulatory or personal advantage, which may constitute an offence under the Act, namely:
- giving or offering a bribe;
- receiving or requesting a bribe; or
- bribing a foreign public official.
The Company may also be liable under the Act if it fails to prevent bribery by an associated person (including, but not limited to Workers) for the Company’s benefit.
Gifts and hospitality
This policy does not prohibit normal and appropriate gifts and hospitality (given and received) to or from Third Parties unless otherwise specifically stated. However, we have specific internal policies and procedures which provide guidance to Workers as to what is to be regarded as normal and appropriate gifts and hospitality in terms of financial limits, subject to the principles set out below (the Overriding Principles), namely that any gift or hospitality:
- must not be made with the intention of improperly influencing a Third Party or Worker to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
- must comply with local law in all relevant countries;
- must be given in the name of the organisation, not in an individual’s name;
- must not include cash or a cash equivalent;
- must be appropriate in the circumstances;
- must be of an appropriate type and value and given at an appropriate time taking into account the reason for the gift;
- must be given openly, not secretly; and
The Company appreciates that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable both in the UK and any other relevant country. The intention behind the gift should always be considered.
What is not acceptable?
It is not acceptable for any Worker (or someone on their behalf) to:
- give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that they or the Company will improperly be given a business advantage, or as a reward for a business advantage already improperly given;
- give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to facilitate or expedite a routine procedure;
- accept payment from a Third Party where it is known or suspected that it is offered or given with the expectation that the Third Party will improperly obtain a business advantage;
- accept a gift or hospitality from a Third Party where it is known or suspected that it is offered or provided with an expectation that a business advantage will be improperly provided by the Company in return;
- threaten or retaliate against another Worker who has refused to commit a bribery offence or who has raised concerns under this policy; or
- engage in any activity that might lead to a breach of this policy.
Facilitation payments and “kickbacks”
We do not make, and will not accept, facilitation payments or “kickbacks” of any kind, such as small, unofficial payments in return for a business favour or advantage.
Charitable Donations and Sponsorship
The Company only makes charitable donations and provides sponsorship that are legal and ethical under local laws and practices and which are in accordance with the Company’s internal policies and procedures.
Record keeping
We keep appropriate financial records and have appropriate internal controls in place which evidence the business reason for gifts, hospitality and payments made and received.
Responsibilities and raising concerns
The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All Workers are required to avoid any activity that might lead to, or suggest, a breach of this policy
Workers are required to notify the Company as soon as possible if it is believed or suspected that a conflict with this policy has occurred, or may occur in the future, or if they are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that they are a victim of another form of unlawful activity.
Any employee who breaches this policy may face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with non-employee Workers if they breach this policy.
If any Third Party is aware of any activity by any Worker which might lead to, or suggest, a breach of this policy, they should raise their concerns with the Company’s Director Charles Magill Charles Magill charles.magill@adlestropconsulting.com
Training and communication
Training on this policy is provided for all Workers and our zero-tolerance approach to bribery and corruption will, where appropriate, be communicated to clients, suppliers, contractors and business partners.
Monitoring and review
The Firm monitors the effectiveness and reviews the implementation of this policy at appropriate intervals, considering its suitability, adequacy and effectiveness. Any improvements identified are made as soon as possible. Internal control systems and procedures are also subject to regular review to provide assurance that they are effective in countering any risks of bribery and corruption.
All Workers are aware that they are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.
Anti-Tax Evasion Policy
In the light of Criminal Finances Act 2017, Adlestrop Consulting Ltd has adopted a statement of our corporate value on anti-facilitation of tax evasion. It is our policy to conduct all of our business dealings in an honest and ethical manner. The value statement governs all our business dealings and the conduct of all persons or organisations who are appointed to act on our behalf.
We request all our employees and all who have, or seek to have, a business relationship with Adlestrop Consulting Ltd, to familiarise themselves with our anti-tax evasion value statement and to act at all times in a way which is consistent with our anti-tax evasion value statement.
ANTI-TAX EVASION VALUE STATEMENT
Adlestrop Consulting Ltd (the “Company”) has a zero tolerance approach to all forms of tax evasion, whether under UK law or under the law of any foreign country.
Employees and Associates of the Company must not undertake any transactions which:
(a) cause the Company to commit a tax evasion offence; or
(b) facilitate a tax evasion offence by a third party who is not an associate of the Company.
We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter tax evasion facilitation.
At all times, business should be conducted in a manner such that the opportunity for, and incidence of, tax evasion is prevented.
WHO MUST COMPLY WITH THIS POLICY?
This policy applies to all persons working for the Company or any subsidiary company or on our behalf in any capacity, including employees at all levels, directors, officers and Associates (as defined below), including but not limited to agency workers, seconded workers, volunteers, interns, contractors, external consultants, third-party representatives and business partners, sponsors or any other person associated with us, wherever located.
WHO IS RESPONSIBLE FOR THIS POLICY?
The Directors of the Company has overall responsibility for ensuring that this policy complies with our legal obligations, and our employees and associates comply with it. This policy is adopted by the Company. It may be varied or withdrawn at any time, in the Company’s absolute discretion. Employees in leadership positions are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it.
WHAT IS THE FACILITATION OF TAX EVASION?
For the purposes of this policy:
Associates includes company contractors or an agent of the Company (other than a contractor) who is acting in the capacity of an agent, or any person who performs services for and on behalf of the Company who is acting in the capacity of a person or business performing such services.
Tax Evasion means an offence of cheating the public revenue or fraudulently evading UK tax, and is a criminal offence. The offence requires an element of fraud, which means there must be deliberate action, or omission with dishonest intent.
Foreign Tax Evasion means evading tax in a foreign country, provided that the conduct is an offence in that country and would be a criminal offence if committed in the UK. As with tax evasion¸ the element of fraud means there must be deliberate action, or omission with dishonest intent.
Tax Evasion Facilitation means being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of tax (whether UK tax or tax in a foreign country by another person, or aiding, abetting, counselling or procuring the commission of that offence. Tax evasion facilitation is a criminal offence, where it is done deliberately and dishonestly.
Tax evasion is not the same as tax avoidance or tax planning. Tax evasion involves deliberate and dishonest conduct. Tax avoidance is not illegal and involves taking steps, within the law, to minimise tax payable (or maximise tax reliefs).
Tax means all forms of UK taxation, including but not limited to corporation tax, income tax, value added tax, stamp duty, stamp duty land tax, national insurance contributions (and their equivalents in any non-UK jurisdiction) and includes duty and any other form of taxation (however described).
COMPANY RESPONSIBILITIES
The Company has completed a risk assessment and has established procedures governing certain transactions with third parties designed to prevent specific areas of possible tax evasion by a third party.
The Company is responsible for offering employees appropriate training to understand tax evasion, and actions to take to prevent tax evasion. The training programme can be requested at any time during employment with Adlestrop Consulting Ltd.
WHAT TEAM MEMBERS AND ASSOCIATES MUST NOT DO
Employees and Associates must at all times adhere to the Adlestrop Consulting Ltd anti-tax evasion value statement and must ensure that they read, understand and comply with this policy.
It is not acceptable for team members and Associates to:
a) Engage in any form of facilitating Tax Evasion or Foreign Tax Evasion
b) Aid, abet, counsel or procure the commission of a Tax Evasion offence or Foreign Tax Evasion offence by another person;
c) Fail to promptly report any request or demand from any third party to facilitate the fraudulent Evasion of Tax by another person, in accordance with this policy; or
d) Engage in any other activity that might lead to a breach of this policy; or
e) Threaten or retaliate against another individual who has refused to commit a Tax Evasion offence or a Foreign Tax Evasion offence or who has raised concerns under this policy
f) An offence under the law of any part of the UK consisting of being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of tax.
PREVENTION THROUGH VIGILANCE
There is not an exhaustive list of Tax Evasion opportunities. At a more general level, the best defence against Tax Evasion and facilitation of Tax Evasion remains the vigilance of our employees and Associates and the adoption of a common-sense approach supported by our clear whistleblowing procedure. In applying common sense, team members must be aware of the following:
- Is there anything unusual about the manner in which an Associate of the Company is conducting their relationship with the Company or the third party (usually a customer)?
- Is there anything unusual about the customer’s or Associate’s conduct or behaviour in your dealings with them?
- Are there unusual payment methods?
Unusual payment methods and unusual conduct of third parties with Company Associates can be indicative that a transaction may not be as it seems.
HOW TO RAISE A CONCERN
Our employees have a responsibility to take reasonable action to prevent harm to Adlestrop Consulting Ltd and we hold our employees accountable for their actions and omissions. Any actions that breach the Criminal Finances Act and the tax laws of wherever we operate brings harm to Adlestrop Consulting Ltd and will not be tolerated.
You are responsible for properly following Adlestrop Consulting Ltd policies and procedures. These should generally ensure that all taxes are properly paid. If you are ever asked by anyone either inside or outside our company to go outside our standard procedures, this should be reported without delay, as someone may be attempting to evade tax.
WHAT HAPPENS IF THE EMPLOYEE PREFERS, FOR COMMERCIAL REASONS, NOT TO REPORT THEIR SUSPICIONS?
This should never happen. If there is any suspicion of any intention to evade tax and the transaction if nevertheless finalised, the Company can be criminally prosecuted, subject to a large fine and be publicly named and shamed.