BS/ ISO MANAGEMENT SYSTEM POLICY MANUAL · BS/ ISO MANAGEMENT SYSTEM POLICY MANUAL Comast...

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COMAST CONSTRUCTION

BS/ ISO MANAGEMENT SYSTEM

POLICY MANUAL

Comast Construction Ltd

Trinity Buoy Wharf

64 Orchard Place

London

E14 0JW


Amendment Schedule

ISSUE DATE DETAILS BY

1 11th Oct

2013

First issue to replace previous Manual/ Polices not

UKAS accredited.

MA Approved by Mauro

Stefanutti

2 Oct 2014 Inclusion of Anti –bribery Policy and revised H&S

Policy MA

3 5th Oct 2015 Inclusion of bullying and harassment in the workplace

policy and procedure MA

4 29th Feb

2016

Amendment of Quality Policy Statement in line with

9001: 2015 standard MA

5 21st June

2016

Amendment of Quality Policy Statement in line with

9001: 2015 standard MA

6

7

8

9

10

11

12


Management System- Policy Manual

DOCUMENT REF: MS-PM ISSUE NO: 5 ISSUE DATE: Jun 2016 APPROVED BY: MS

TITLE: Structure of the Management System

Introduction

Comast Construction Limited (the organisation) was founded in 1999 and provides a wide

range of Professional Services associated with its core business (Building) and has had

extensive experience in the subsequent Management of all types of New Build and Civil

Engineering Projects within London and the South East. The organisation is able to carry out all

Builders work and provide construction services.

To verify and demonstrate the strong foundations and belief of the organisation, certification

and accreditations have been achieved, including BS EN ISO 9001:2015 & BS OHSAS

18001:2007.

The ISO Management System- Scope of Registration is:

General Ground and associated Concrete Works, Concrete Structures, Special Concrete Repairs

including Diamond Cutting and Interior Fitout and Refurbishment and Back up Services.

The control measures described within this Management System, shall be applied consistently

throughout the organisation.

The activities of Comast Construction Ltd are managed from the permanent Head office at

Trinity Buoy Wharf, London and operationally on temporary construction sites.

The Comast Construction Management System is based upon the requirements of…

- BS EN ISO 9001:2015 - Quality Management Systems

- BS EN ISO 14001:2015 – Environmental Management Systems

- BS OHSAS 18001: 2007- Occupational Health and Safety Management Systems

The organisation is not generally responsible for design elements of their undertaking, these

are generally provided by the Client, Principal Contractor or are out sourced to a specialist

designer however temporary works design is a requirement for a large part of the works and

as such “Rees Design Partnership” services are utilised for this element of work where clear

records of information in/ information out shall be maintained by Comast Construction in

relation to any temporary works designs.

All other clauses of the standards that Comast Construction claim conformity to are applicable.

The nominated ISO integrated management system Manager is Narinderjit Sahota; with

ultimate responsibility remaining with Mauro Stefanutti (MD).





Structure of the Management System

The Management System is structured in three levels, described below…

1. Policy Manual (including this document)

This manual is the “Top Level” within the ISO management system. This

document is deliberately concise, laying out just the Scope, Exclusions and

basic activities of the organisation, along with a description of the Process

Interaction.

A Health and Safety Policy document is also maintained, which is cross

referenced from Level 1 and Level 2 documents, such as the ISO Policy

Manual and Operational Procedures.

2. Procedures

The ‘Second Level’ of the ISO Management System comprises of Work

Instructions, either in ‘Written Procedure’ or ‘Flow Chart’ form. The

purpose of these procedures is to ensure key Processes of the company

are operated in an appropriate and consistent manner, by all persons

involved.

Procedures as required to suitably control the Company’s Processes, have

been introduced and are listed in the Document Control list.

The Procedures shall be made available, in relation to the activity being

undertaken and must be adhered to, too ensure the consistency of

service/ product. If a procedural improvement, or change is identified, this

is to be discussed with the Appropriate Manager, who will make

amendments, as necessary.

3. Process Control Measures

Each of the Processes is administered through defined ‘Control Measures’.

This ‘Third level’ comprises for example, Computer Databases, Standard

Forms, Project Specifications, and other Paperwork Systems. The purpose

of these systems is to ensure information is effectively recorded, and

communicated. Traceability throughout the process must be maintained

through the proper implementation of these control measures.

All Standard Process Documentation is listed on the Document Control

List.





Overview & Interaction of the Company’s Processes.

The schematic below outlines the sequence and interaction of the organisations processes and illustrates how the operation of the BS/ISO management system aims to achieve Compliance and Continual Improvement….

NB; the above representation of process sequence/interaction demonstrates the order in which activities are undertaken. This in not intended to directly correlate with procedural titles, as these are defined separately on the Document Control List.

Planning ‘’Resource

Management’’ PQQ/ Tender/

Contractual Agreement

Doing ‘’Product Realisation’’

Site surveys, agreed specification, programming of works, pre-start stages, purchasing & receipt of

materials, liaison with third parties

Act ‘’Management Responsibility’’

Process performance is monitored, complaints, feedback, audits are

reviewed and followed up. Processes developed and

objectives defined.

Checking ‘’Monitoring & Measurement’’

Final inspection, completion & handover, costings, valuations and

invoicing.

Establishing legal requirement, risks, aspects, impacts & operational control

Sub-Contract Management &

Instruction

Customer

Requirement

Input to Process Customer Enquiry.

Customer feedback, internal auditing, safety monitoring,

Evaluation of Compliance

Waste Management (Duty of Care)

Output from Process Product/ Service Delivery

Customer

Satisfaction

Continual

Improvement


Construction Process Map inclusive of Duty Holders Responsibilities




TITLE: Environment Policy Statement- BS EN ISO 14001:2004

Comast Construction Limited (The Organisation) realise the importance of maintaining

operations to ensure the safety of the Environment. The Organisation recognises that effective

management of our activities makes good business sense and will be fundamental to and is a

part of our business strategy that shall be communicated to all personnel working for or on

behalf of the Organisation.

To ensure we achieve these standards, procedures will be implemented to include the

following:

Being aware of how our activities impact the environment, to seek and minimise

adverse effects by means of the best practices and available techniques, not entailing

excessive cost, through a Policy of Quality, Health and Safety, and Environmental

improvement in the workplace, prevention of pollution and care for the local

Environment.

To comply with our legal responsibilities and play a part in future legislation.

Conserve the use of resources, particularly those that are scarce or non-renewable.

To avoid waste and encourage conservation, re-use and re-cycling. e.g.

Conservation and Waste disposal Management to preserve, restore and enhance the

built and natural heritage.

To encourage the sustainable use of land based resources and certified timber and

wood products.

To reduce air, land and water pollution e.g. toxic chemical sprays, motor exhaust.

Being sensitive to the Environmental concerns of our Clients and Community

through which we operate and responding to them.

Adopting Environmental objectives to continually improve our Environmental

performance and monitor the progress of achievement.

Using Supplies and Practices and a proper regard for the way we operate by

disposing of waste materials as required by current legislation and to communicate

this policy to all our Staff.

To meet this commitment, the Organisation will operate under the control of an

Environmental System laid down in the ISO 14001:2004 series of standards. It is

the Company’s objective to seek to operate this Environmental Policy continuously

and to implement and operate fully the ISO 14001:2004 Standard through

registration and annual review.

Signed: Date: 21st June 2016 Mauro Stefanutti, Managing Director




TITLE: Quality Policy Statement- BS EN ISO 9001:2015

The following continues to be our Quality Policy and applies to ALL of the work we undertake,

whatever its nature.

We will work to the highest Quality and other Standards relevant to our Clients’ interests and

project requirements. This work will be completed in accordance with our own high

expectations and goals, which are:

Ensuring Client satisfaction

Complying with all legal and other applicable requirements

Assurance of a high standard of product and service

Offering a complete service that is professional and proactive

Consistently and reliably paying all due attention to detail.

To achieve these high expectations and objectives Comast Construction Ltd calls upon its

workforce to work in conjunction with the client to reach the Client’s expectations for each

project.

To meet this commitment, Comast Construction Ltd will operate under the requirements of a

Process-based Quality Management System certified to ISO 9001:2015 relevant to the nature

of our business, and will monitor our programmes of work through regular project inspections,

procedural review and independent auditing ensuring that appropriate resources and

infrastructure are provided and that roles and authorities are established and communicated

throughout the organisation.

We also commit ourselves to continual improvement of the effectiveness of our quality

management system and when required, introduce new procedures in a timely manner. We

will uphold customer focus through demonstrating leadership and commitment; ensuring that

customer requirement and satisfaction are determined and monitored and that risks and

opportunities that can affect conformity are determined, understood and are consistently met.

We will establish suitable quality objectives and review them to ensure they remain pertinent

to our business, by consulting and communicating with our workforce.

It remains Comast Construction Ltd.’s belief that in applying the Management Procedures

within our Quality Management System, we will consistently meet the requirements of our

customers, stakeholders, other interested parties and the Construction Industry.

Signed: Date: 21st June 2016

Mauro Stefanutti, Managing Director

(Person responsible for implementing this policy)



DOCUMENT REF: MS-PM ISSUE NO: 6 ISSUE DATE: Oct 2016 APPROVED BY: MS

TITLE: Health and Safety Policy Statement- BS OHSAS 18001:2007

The Company recognises its responsibilities under the Health and Safety at Work etc. Act 1974 and other relevant safety legislation and other requirements with regards to its employees and others who may be affected by our undertaking. The Company also recognises that Health and Safety should be considered equally with quality and performance when work is being considered or undertaken. The Company will provide such information, training, supervision, plant and equipment as necessary, to identify, eliminate or control hazards and risks at the workplace. Adequate resources will be provided for this purpose. The overall objective is to prevent injury and ill health to all employees and those affected by our activities and to strive for continual improvement in the management of our occupational health and safety performance. Any Company employee who supervises or manages the use of work equipment shall have received adequate training for the purposes of health and safety, including training in the methods that may be adopted when using the work equipment, any risks that such use may entail and precautions to be taken. All employees and sub-contractors are expected to co-operate with the Company in carrying out this Policy and must ensure that their own work, so far as is reasonably practicable, is carried out without risk to themselves or others. Mauro Stefanutti has been appointed as having particular responsibility for Health, Safety and Welfare and is to whom reference should be made in the event of any difficulty arising in the implementation of this Policy. The Management and staff of the Company will monitor the operation of this Policy to encourage and strive for continual improvements in health and safety performance as an on-going action. To assist in this respect, the Company has appointed Martin Apps as Safety Advisor to give advice on the requirements of the relevant statutory provisions and safety matters and, on request, to visit sites and workplaces to ensure compliance. This Statement of Company Policy will be displayed prominently or made available at all sites and workplaces. In addition, the Organisation and Arrangements for implementing the Policy will also be available at each site and workplace. A full copy of the Policy is held at, Comast Construction Ltd, Trinity Buoy Wharf, 64 Orchard Place, London, E14 OJW for reference by any employee as required. This Policy will be reviewed on an annual basis to reflect any changes in legislation. Signed (on behalf of Comast):

Mauro Stefanutti Managing Director Date: 6th October 2016 Review: October 2017




TITLE: Drugs and Alcohol Policy Statement

The Company recognises the potential dangers of alcohol, drug and solvent abuse, known as

substance abuse, to both the individual and the Company.

The Company aims to prevent, where possible, alcohol, drug and solvents abuse amongst

employees and sub-contractors and to detect at an early stage, employees with problems.

The Company will offer assistance such as counselling and will normally deal with the matter in

confidence as a health issue. We will try to deal with cases of alcohol or drug misuse

supportively, but there may be circumstances where this is not possible or appropriate. We

may then use the disciplinary or performance review procedure.

Rules

All persons working for the Company directly or indirectly must not:-

a) Use, posses, conceal, distribute or otherwise be involved with illegal drugs and

abusive use of chemicals or controlled substances whilst on the Company premises

or worksites. Such situations will be reported to the Police immediately.

b) Shall not consume alcohol whilst on Company premises or worksites and must not

report for work whilst under the influence of alcohol.

Employees who are required to take “over the counter” medically prescribed drugs must be

aware of any side effects that may influence their performance and must report this to their

line manager.

Screening

Screening for drugs and alcohol maybe undertaken as follows:-

a) Following a workplace accident/ incident.

b) If there is reasonable suspicion based on behaviour.

c) Random testing or any testing required by our clients.

Any testing will be undertaken by our nominated independent specialist consultants.

N.B.

Failure to comply with this Policy or submit to a test will lead to disciplinary action and/ or

dismissal.

This Statement of Company Policy will be displayed prominently or made available at all sites

and workplaces.

This Policy will be reviewed regularly in consultation with employee representatives and to

reflect any changes in legislation.

Signed (on behalf of Comast):

Mauro Stefanutti

Managing Director Date: 22st June 2016




TITLE: Smoke Free Policy

Smoke Free Policy

This Policy has been developed to protect all employees, service users, clients and visitors

from the effects of second- hand smoke and to assist in compliance with the Health Act 2006.

Exposure to second- hand smoke increases the risk of lung cancer, heart disease and other

serious illness. Ventilation and separating smokers from non- smokers in the same airspace

does not completely prevent potentially dangerous exposures.

It is the Policy of Comast Construction Ltd that all of our workspaces are smoke free, and that

all employees have a right to work in a smoke free environment. This Policy comes into effect

on 1st January 2013. Smoking is prohibited in all enclosed and substantially enclosed

workplaces and premises. This includes all Company vehicles.

This Policy applies to all employees, contractors, clients and visitors.

Overall responsibility for the implementation of this Policy rests with the line Managers.

However all Staff are obliged to adhere to, and support the implantation and monitoring of this

Policy. They will additionally ensure all new personnel are aware of this policy on recruitment/

induction.

Appropriate signage will be clearly displayed at entrances to and in premises and vehicles.

Local disciplinary procedures will be followed if a member of staff fails to comply with this

Policy. Those who do not comply with the smoke-free law may also be liable to a fixed penalty

fine and possible criminal prosecution.

The NHS offers a range of free services to help smokers give up. Visit smokefree.nhs.uk or call

the NHS Smokers helpline on 0800 0224332 for details.

This Company Policy will be displayed prominently or made available at all sites and

workplaces.

This Policy will be reviewed on an annual basis to reflect any changes in legislation.


Mauro Stefanutti

Managing Director

Date: 21st June 2016




TITLE: Anti-Bribery Policy Statement

Bribery is a criminal offence. We do not, and will not, pay bribes or offer improper inducements

to anyone for any purpose, nor do we or will we, accept bribes or improper inducements.

To use a third party as a conduit to channel bribes to others is a criminal offence. We do not,

and will not, engage indirectly in or otherwise encourage bribery.

We are committed to the prevention, deterrence and detection of bribery. We have zero

tolerance towards bribery. We aim to maintain anti-bribery compliance “business as usual”,

rather than as a one-off exercise.

Objective of this policy

This policy provides a coherent and consistent framework to enable the organisation’s

employees to understand and implement arrangements enabling compliance. In conjunction

with related policies and key documents it will also enable employees to identify and effectively

report a potential breach.

We require that all personnel, including those permanently employed, temporary agency

staff and contractors:

• act honestly and with integrity at all times and to safeguard the organisation’s

resources for which they are responsible

• comply with the spirit, as well as the letter, of the laws and regulations of all

jurisdictions in which the organisation operates, in respect of the lawful and responsible

conduct of activities

Scope of this policy

This policy applies to all of the organisation’s activities. For partners, joint ventures and

suppliers, we will seek to promote the adoption of policies consistent with the principles set out

in this policy.

Within the organisation, the responsibility to control the risk of bribery occurring resides at all

levels of the organisation.

This policy covers all personnel, including all levels and grades, those permanently employed,

temporary agency staff, contractors, non-executives, agents, Members (including independent

members), volunteers and consultants.

This organisation’s commitment to action

This organisation commits to:

• Setting out a clear anti-bribery policy and keeping it up to date

• Making all employees aware of their responsibilities to adhere strictly to this policy at

all times

• Training all employees so that they can recognise and avoid the use of bribery by

themselves and others

• Encouraging its employees to be vigilant and to report any suspicions of bribery,

providing them with suitable channels of communication and ensuring sensitive

information is treated appropriately


• Rigorously investigating instances of alleged bribery and assisting police and other

appropriate authorities in any resultant prosecution

• Taking firm and vigorous action against any individual(s) involved in bribery

• Provide information to all employees to report breaches and suspected breaches of

this policy

• Include appropriate clauses in contacts to prevent bribery.

Bribery

Is an inducement or reward offered, promised or provided to gain personal, commercial,

regulatory or contractual advantage.

The Bribery Act

There are four key offences under the Act:

• bribery of another person (section 1)

• accepting a bribe (section 2)

• bribing a foreign official (section 6)

• failing to prevent bribery (section 7)

The Bribery Act 2010 (http://www.opsi.gov.uk/acts/acts2010/ukpga_20100023_en_1) makes

it an offence to offer, promise or give a bribe (Section 1). It also makes it an offence to

request, agree to receive, or accept a bribe (Section 2). Section 6 of the Act creates a separate

offence of bribing a foreign public official with the intention of obtaining or retaining business

or an advantage in the conduct of business. There is also a corporate offence under Section 7

of failure by a commercial organisation to prevent bribery that is intended to obtain or retain

business, or an advantage in the conduct of business, for the organisation. An organisation will

have a defence to this corporate offence if it can show that it had in place adequate procedures

designed to prevent bribery by or of persons associated with the organisation.

Are we a “commercial organisation”?

The guidance states that a “commercial organisation” is any body formed in the United

Kingdom and “...it does not matter if it pursues primarily charitable or educational aims or

purely public functions. It will be caught if it engages in commercial activities, irrespective of

the purpose for which profits are made. ”We are a “commercial organisation”.

What are “adequate procedures”?

Whether the procedures are adequate will ultimately be a matter for the courts to decide on a

case-by-case basis. Adequate procedures need to be applied proportionately, based on the

level of risk of bribery in the organisation. It is for individual organisations to determine

proportionate procedures in the recommended areas of six principals. These principles are not

prescriptive. They are intended to be flexible and outcome focussed, allowing for the different

circumstances of organisations. Small organisations will, for example, face different challenges

to those faced by large multi-national enterprises. The detail of how organisations apply these

principles will vary, but the outcome should always be robust and effective anti-bribery

procedures.

Proportionate procedures

An organisation’s procedures to prevent bribery by persons associated with it are proportionate

to the bribery risks it faces and to the nature, scale and complexity of the organisation’s

activities. They are also clear, practical, accessible, effectively implemented and enforced.

Top level commitment

The top-level management (be it a board of directors, the owners or any other equivalent body

or person) are committed to preventing bribery by persons associated with it. They foster a

culture within the organisation in which bribery is never acceptable.

http://www.opsi.gov.uk/acts/acts2010/ukpga_20100023_en_1


Risk Assessment

The organisation assesses the nature and extent of its exposure to potential external and

internal risks of bribery on its behalf by persons associated with it. The assessment is periodic,

informed and documented. It includes financial risks but also other risks such as reputational

damage.

Due diligence

The organisation applies due diligence procedures, taking a proportionate and risk based

approach, in respect of persons who perform or will perform services for or on behalf of the

organisation, in order to mitigate identified bribery risks.

Communication (including training)

The organisation seeks to ensure that its bribery prevention policies and procedures are

embedded and understood throughout the organisation through internal and external

communication, including training that is proportionate to the risks it faces.

Monitoring and review

The organisation monitors and reviews procedures designed to prevent bribery by persons

associated with it and makes improvements where necessary.

This organisation is committed to proportional implementation of these principles.

Penalties

An individual guilty of an offence under sections 1, 2 or 6 is liable:

• On conviction in a magistrates court, to imprisonment for a maximum term of 12

months, or to a fine not exceeding £5,000, or to both

• On conviction in a crown court, to imprisonment for a maximum term of ten years,

or to an unlimited fine, or both

Organisations are liable for these fines and if guilty of an offence under section 7 are liable to

an unlimited fine.

Bribery is not tolerated

It is unacceptable to:

• give, promise to give, or offer a payment, gift or hospitality with the expectation or

hope that a business advantage will be received, or to reward a business advantage

already 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 that you know or suspect is offered with the

expectation that it will obtain a business advantage for them

• accept a gift or hospitality from a third party if you know or suspect that it is offered

or provided with an expectation that a business advantage will be provided by us in

return

• retaliate against or threaten a person who has refused to commit a bribery offence or

who has raised concerns under this policy

• engage in activity in breach of this policy.

Facilitation payments

Facilitation payments are not tolerated and are illegal. Facilitation payments are unofficial

payments made to public officials in order to secure or expedite actions.


Gifts and hospitality

This policy is not meant to change the requirements of our gifts and hospitality policy. This

makes it clear that: (e.g. alternatives)

- no gift or hospitality is to be offered or accepted

- nominal gifts and hospitality up to a financial value of £25 are acceptable

- reasonable, proportionate gifts and hospitality made in good faith and that are not

lavish are acceptable.

Public contracts and failure to prevent bribery

Under the Public Contracts Regulations 2006 (which gives effect to EU law in the UK), a

company is automatically and perpetually debarred from competing for public contracts where

it is convicted of a corruption offence. There are no plans to amend the 2006 Regulations for

this to include the crime of failure to prevent bribery. Organisations that are convicted of

failing to prevent bribery are not automatically barred from participating in tenders for public

contracts. This organisation has the discretion to exclude organisations convicted of this

offence.

Staff responsibilities

The prevention, detection and reporting of bribery and other forms of corruption are the

responsibility of all those working for the organisation or under its control. All staff are required

to avoid activity that breaches this policy.

You must:

• ensure that you read, understand and comply with this policy

• raise concerns as soon as possible if you believe or suspect that a conflict with this

policy has occurred, or may occur in the future.

As well as the possibility of civil and criminal prosecution, staff that breach this policy will face

disciplinary action, which could result in dismissal for gross misconduct.

Raising a concern

This organisation is committed to ensuring that all of us have a safe, reliable, and confidential

way of reporting any suspicious activity. We want each and every member of staff to know

how they can raise concerns.

We all have a responsibility to help detect, prevent and report instances of bribery. If you have

a concern regarding a suspected instance of bribery or corruption, please speak up – your

information and assistance will help. The sooner you act, the sooner it can be resolved.

There are multiple channels to help you raise concerns. Please refer to the Whistleblowing

policy and determine your favoured course of action. Preferably the disclosure will be made

and resolved internally. Secondly, where internal disclosure proves inappropriate, concerns can

be raised with the regulator (e.g. external auditor. See link to “BIS prescribed persons” at the

end of this document). Raising concerns in these ways may be more likely to be considered

reasonable than making disclosures publicly (e.g. to the media).

Concerns can be anonymous. In the event that an incident of bribery, corruption, or

wrongdoing is reported, we will act as soon as possible to evaluate the situation. We have

clearly defined procedures for investigating fraud, misconduct and non-compliance issues and

these will be followed in any investigation of this kind. This is easier and quicker if concerns

raised are not anonymous.

Staff who refuse to accept or offer a bribe, or those who raise concerns or report wrongdoing

can understandably be worried about the repercussions. We aim to encourage openness and


will support anyone who raises a genuine concern in good faith under this policy, even if they

turn out to be mistaken.

We are committed to ensuring nobody suffers detrimental treatment through refusing to take

part in bribery or corruption, or because of reporting a concern in good faith.

If you have any questions about these procedures, please contact Mauro Stefanutti 0207 537

6022.

Other relevant policies

All other company policies remain applicable and should be read in conjunction with this policy.

Useful links

CIPFA Better Governance Forum CIPFA Better Governance Forum - CIPFA Networks

The Bribery Act Bribery Act 2010

Approved by:

Mauro Stefanutti

Managing Director

21st June 2016




TITLE: Corporate and Social Responsibilities

We at Comast Construction Limited recognise that we must integrate our business values and

operations to meet the expectations of our stakeholders. They include customers, employees,

investors, suppliers, the community and the environment.

We recognise that our social, economic and environmental responsibilities to these

stakeholders are integral to our business. We aim to demonstrate these responsibilities

through our actions and within our corporate policies.

We take seriously all feedback that we receive from our stakeholders and, where possible,

maintain open dialogue to ensure that we fulfil the requirements outlined within this policy.

We shall be open and honest in communicating our strategies, targets, performance and

governance to our stakeholders in our continual commitment to sustainable development.

The Managing Director is responsible for the implementation of this policy and will make the

necessary resources available to realise our corporate responsibilities. The responsibility for

our performance on this policy rests with all employees throughout the company.

Our partnership focus:

We shall ensure a high level of business performance while minimising and effectively

managing risk ensuring that we uphold the values of honesty, partnership and fairness in

our relationships with all our stakeholders

We shall support the development of our external stakeholders through led training courses

and using our facilities for all of our business partners to hold seminars and industry

meetings

Our contracts will clearly set out the agreed terms, conditions and the basis of our

relationship and will operate in a way that safeguards against unfair business practices

We shall encourage suppliers and contractors to adopt responsible business policies and

practices

We shall encourage dialogue with local communities for mutual benefit

We will register and resolve customer complaints in accordance with our standards of

service.

We shall support and encourage our employees to help local community organisations and

activities in our region, particularly our employee chosen charities

We shall work with local schools, colleges and universities to assist young people in

choosing their future careers, being an advocate for our industry

We shall operate an equal opportunities policy for all present and potential future

employees and will offer our employees clear and fair terms of employment and provide

resources to enable their continual development

We shall maintain a clear and fair employee remuneration policy and shall maintain forums

for employee consultation and business involvement

We shall provide safeguards to ensure that all employees of whatever nationality, colour,

race or religious belief are treated with respect and without sexual, physical or mental

harassment

We shall provide, and strive to maintain, a clean, healthy and safe working environment in

line with our Health and Safety policy and safe systems of work

We have developed Environmental policies and objectives as part of the business planning

cycle.

Approved by:

Mauro Stefanutti

Managing Director Date: 21st June 2016




TITLE: Ethics Policy

It is the policy of Comast Construction Ltd that its employees and board members uphold the

highest standards of ethical, professional behaviour. To that end, these employees and board

members shall dedicate themselves to carrying out the mission of this organisation and shall:

Hold paramount the safety, health and welfare of the public in the performance of

professional duties.

Act in such a manner as to uphold and enhance personal and professional honour, integrity

and the dignity of the profession.

Treat with respect and consideration all persons, regardless of race, religion, gender,

sexual orientation, maternity, marital or family status, disability, age or national origin.

Engage in carrying out Comast’s mission in a professional manner.

Collaborate with and support other professionals in carrying out Comast’s mission.

Build professional reputations on the merit of services and refrain from competing unfairly

with others.

Recognise that the chief function of Comast at all times is to serve the best interests of its

constituency.

Accept as a personal duty the responsibility to keep up to date on emerging issues and to

conduct themselves with professional competence, fairness, impartiality, efficiency, and

effectiveness.

Respect the structure and responsibilities of the board of directors, provide them with facts

and advice as a basis for their making policy decisions, and uphold and implement policies

adopted by the board of directors.

Keep the community informed about issues affecting it.

Conduct organisational and operational duties with positive leadership exemplified by open

communication, creativity, dedication, and compassion.

Exercise whatever discretionary authority they have under the law to carry out the mission

of the organisation.

Serve with respect, concern, courtesy and responsiveness in carrying out the organisation’s

mission.

Signed: Date: 21st June 2016 Mauro Stefanutti, Managing Director




TITLE: Equal Opportunity Policy Statement

The aims of this policy are to ensure that:

Comast Construction Ltd is committed to building an organisation that makes full use of

the talents, skills, experience, and different cultural perspectives available in a multi-

ethnic and diverse society, and where people feel they are respected and valued, and can

achieve their potential regardless of race, colour, nationality, national or ethnic origins,

sexual orientation, gender, disability or age.

Comast Construction Ltd will follow the recommendations of the Statutory Codes of

Practice of both the Commission for Racial Equality and the Equal Opportunities

Commission, and the Disability Rights Commission’s Code of Practice in Employment and

Occupation, in all their employment policies, procedures and practices.

No-one receives less favourable treatment, on grounds of race, colour, nationality, ethnic

or national origins, gender, sexual orientation, religion or belief, disability or age; or is

disadvantaged by any conditions, requirements, provisions, criteria, procedures or

practices that cannot be justified on any other grounds, or victimised for taking action

against any form of discrimination or harassment, or instructed or put under pressure to

discriminate against, or harass, someone on the above grounds.

The organisation is free of unwanted conduct that violates the dignity of workers or

creates an intimidating, hostile, degrading, offensive, or humiliating environment.

Opportunities for employment, training and promotion are equally open to male and

female candidates, candidates from all racial groups, candidates with or without

disabilities, and candidates of any age, and of any sexual orientation, religion or belief.

Selection for employment, promotion, transfer, training, and access to benefits, facilities

and services, will be fair and equitable, and based solely on merit.

This policy applies to all aspects of employment, from recruitment to dismissal and former

workers’ rights.

We will take the following steps to put the policy into practice and make sure that it is

achieving its aims:

1. The policy will be a priority for the organisation.

2. Mauro Stefanutti, Managing Director will be responsible for the day to day operation of the

policy.

3. The policy will be communicated to all workers and job applicants.

4. Workers and their representatives and trade unions will be consulted regularly about the

policy, and about related action plans and strategies.

5. All workers will be trained on the policy, on their rights and responsibilities under the

policy, and on how the policy will affect the way they carry out their duties. No-one will be

in any doubt about what constitutes acceptable and unacceptable conduct in the

organisation.


6. Managers and workers in key decision-making areas will be trained on the discriminatory

effects that provisions, practices, requirements, conditions, and criteria can have on some

groups, and the importance of being able to justify decisions to apply them.

7. Complaints about discrimination or harassment in the course of employment will be

regarded seriously, and may result in disciplinary sanctions, and even dismissal. The

complaints procedure will be published in a form that is easily accessible.

8. Opportunities for employment, promotion, transfer and training will be advertised widely,

internally and externally, and all applicants will be welcomed, irrespective of race, colour,

nationality, ethnic or national origins, gender, sexual orientation, disability or age, religion

or belief.

9. All workers will be encouraged to develop their skills and qualifications, and to take

advantage of promotion and development opportunities in the organisation.

10. Selection criteria will be entirely related to the job or training opportunity.

11. We will make reasonable changes to overcome physical and non-physical barriers that

make it difficult for disabled employees to carry out their work, and for disabled customers

to access our services.

12. We will take a flexible approach to working arrangements. We will consider requests for

changes carefully and objectively, and will accommodate them unless it would cause

significant difficulties to the business or the employee.

13. Information on the ethnic and racial background, gender, disability, and age of each

worker and applicant for employment, promotion and training will be collected and

analysed, to monitor each stage of the recruitment process. The information will be held in

strictest confidence and will only be used to promote equality of opportunity. Information

about the religion/belief and sexual orientation of employees may also be monitored.

14. If the data shows that people from particular groups re under-represented in particular

areas of work, lawful positive action training and encouragement will be considered for

workers and others from that group, to improve their chances of applying successfully for

vacancies in these areas.

15. Grievances, disciplinary action, performance assessment, and terminations of

employment, for whatever reason, will also be monitored by gender, racial group, age,

disability, religion/belief and sexual orientation.

16. Requirements, conditions, provisions, criteria, and practices will be reviewed regularly, in

the light of the monitoring results, and revised if they are found to, or might, unlawfully

discriminate on any of the above grounds.

17. All contracts between Comast Construction Ltd and contractors to supply goods, materials

or services will include a clause prohibiting unlawful discrimination or harassment by

contractors and their staff, and by any sub-contractors and their staff. The clause will also

encourage contractors and potential contractors to provide equality of opportunity in their

employment practices.

18. The effectiveness of the policy will be monitored regularly. A report on progress will be

produced each year, and published via the intranet, the website, the staff newsletter,

notice boards, and the annual report.

19. Customers and clients will be made aware of the policy, and of their right to fair and equal

treatment, irrespective of race, colour, nationality, national or ethnic origins, sexual

orientation, gender, religion/belief, disability or age.


20. The company will draw up an Action Plan detailing how this policy will be implemented in

practice. This policy has been endorsed by Mauro Stefanutti and has the full support of the

management / board.

The policy was approved following consultation with senior managers, workers, workers’

representatives, and trade unions.

Overall responsibility for the effectiveness of the policy lies with Mauro Stefanutti, Comast

Construction Ltd, Trinity Buoy Wharf, 64 Orchard Place, London, E14 OJW Telephone: 0207

537 6022


Mauro Stefanutti

Managing Director

Date: 21st June 2016




TITLE: Bullying and Harassment in the Workplace

Policy Statement

Workplace Conduct:

Bullying and harassment is not acceptable or tolerated in our workplaces. All workers will be

treated in a fair and respectful manner.

Bullying and harassment:

(a) Includes and inappropriate conduct or comment by a person towards a worker that the

person knew or reasonably knew or reasonably ought to have known would cause that

worker to be humiliated or intimidated, but

(b) (b) excludes any reasonable action taken by an employer or supervisor relating to the

management and direction of workers or the place of employment

Examples of conduct or comments that might constitute bullying or harassment include verbal

aggression or insults, calling someone derogatory names, harmful hazing or initiation

practices, vandalising personal belongings, and spreading malicious rumours.

Workers Must:

Not engage in the bullying and harassment of other workers

Report if bullying and harassment is observed or experienced

Apply and comply with the Companies Policies and procedures on bullying and

harassment

Application:

This Policy Statement applies to all workers, including permanent, temporary, casual, contract,

and student workers. It applies to interpersonal and electronic communications, such as email.

Annual review:

This Policy Statement will be reviewed annually. All workers will be provided with a copy.

Signed: Date: 21st June 2016

Mauro Stefanutti, Managing Director

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