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Good Morning/Afternoon,

We hope that you arewell and that you, your family, and all those you work with, andtheir families are also safe and well.

The situation we find ourselves in is like nothing people have experienced before; andit is nothing that businesses have experienced before. Things are changing gradually,and the lockdown is easing in different ways but, per government guidelines, we allneed to continue to exercise the 2metres social distancing rules.

Firmsnow face problems similar to the government to considerrestarting theirofficeoperations amid economic and human concern.

An essential thing that you, as a SeniorManagement Team, must bear in mind as thegovernment restrictions are lifted is that your legal duty to safeguard your employeesand customers are not eased; they are enhanced. Firms need a plan to resumeworkplace activities in a controlled and safe manner, if some activities cannot becarried out safely, they should not be undertaken at all. Employers have a duty of careto support the many people continuing to work from home, to help those transitioningback to workplaces and protect psychological safety as they do.

The Health and Safety at WorkAct 1974 (HSWA)remains the primary legislationgoverning health and safety in the workplace. HSWA requires employers to do all that

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is “reasonablypracticable” to reduce the riskwithin the workplace for their employeesand anyone else affected. An employer must provide an adequate system andensure that employees follow it, through management, instruction, incentivisation andultimately discipline. Liability is non-delegable, ensuring safe systems are implementedand followed by staff is as important as the risk assessment determining what a safesystem looks like.

Businessesandworkplaces should encourage their employees to work at home,wherever possible. If you cannot work from home, then you can still travel to work.

Most firms were able to quickly switch to a full or part homeworking model duringthe lockdown and HSEguidanceon homeworkers should continue to be followedincluding conducting a risk assessment on all homeworkers. Compliance withGovernment guidance will be good evidence of what is reasonably practicable and islikely to set the standard required by the Health and Safety Executive (HSE)in terms ofits enforcement action.

As an employer you should be doing what you can to facilitate home-working. Thatcould be by providing equipment or perhaps accepting less than ideal performance,particularly where employees are vulnerable or extremely vulnerable.An instruction towork from home, potentially performing different tasks,would usually be a reasonableinstruction and employees would be under a general obligation to comply, providedthe employer puts in place suitable homeworking arrangements.

Firms are responsible for ensuring their staff are familiar with both their ownresponsibilities and conduct as a Homeworker and the responsibilities of theiremployer. Despite the increase in associated risks as a regulated firm you are stillresponsible for ensuring that customer needs are met, data is protected under currentregulations, there is effective supervision and management of staff so that staff alwaysact honestly, fairly and professionally and that the health and safety of staff is beingappropriately managed. Please find enclosed information about our standaloneHomeworkingWorkoutmodule which will help in evidencing that you have trainedyour staff on the homeworking factors that could lead to the various health and safetyand code of conduct issues,please also refer to the Covid-19Hub of our ComplianceLibrary for a sample Homeworker RiskAssessment and example Homeworking Policy.

Now, your SeniorManagement Team is responsible for determining the firm’s futureworkingmodel and possible implementation of the reverse BCP.

Compliance cannot be overlooked and the focus on staff,customers and culture underSMCRhas never been more directly relevant. There are many commentaries talking

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about what firms need to do to survive and get back to work; this refers not just toSMCR,but basic economics.

Before the return to the workplace there aremany things to consider.The resultingconsultation, assessment,decision & implementation processes that should befollowed must be documented and managed by the seniormanagement team:

1. Who needs to return to the workplace now &why?

2. How will you keep those staff safe?

3. What physical & protocol changes need to be implemented to ensure a safeworkingenvironment for all?

4. Has your firm’s BusinessContinuity Plan been reviewed and updated?

5. Has your RiskRegister been updated?

Whilst many staffmay fear the idea of returning to the officeotherswill welcome it.

You should review your return to work documentation and process,considerintroducing a Covid-19 policy (or Covid-19 return to work policy) and always refer tothe most up to date government guidance for employers and businesses and HSEguidance managing risksand riskassessmentat work. Health and safety policiesand procedures should also be reviewed to ensure they are up to date with HSElatestinformationand advice. First and foremost, employee safety is paramount. Your FirstAiders and FireMarshals may require refresher training to ensure they are fully up todate with any new procedures relating to the risksof Covid-19,you should consider howthis will be achieved and the procedures followed. As an employer you should alsoconsider that you may need to take steps to maintain the appropriate first aider and firemarshal cover notwithstanding heightened levels of Covid-19sickness absence andfollow HSEguidance for this risk.

If you do decide to restart,manage the risk and bring some or all staff back into theoffice it is good practice to have a person in charge of ensuring that the rules andprocedures are being followed, gather feedback and ensure that staff have an easyway to raiseany concerns they may have. This appointment would normally be aperson or persons within the existing management team, any persons appointed mustbe fully conversantwith the company’s Covid policies and procedures to aid effectiveapplication within the workplace.

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For a gradual restart, you should think about bringing people in progressively, and youmust consider that your staff will need to be trained, or at least inducted, on the newworking arrangements. It is also for firms to understand and, importantly, to support themental wellbeing of their staff:many may fear for their own health or their loved ones’,and some may be grieving. Government guidance,NHS advice and HSEguidanceregarding Mental Health should be followed. Did you know that Avensure is currentlyhosting an accredited Mental Health AwarenessCourse(half day) over 4 days in Juneat just £89+VAT?Please find enclosed copy of email with the course details. We canalso host this specifically for your supervisors and managers if required – please emailhs@avensure.com for more information.

Important Note: Aspart of your planning for the next stage of your firm’smanagement of the impacts of the Covid-19pandemic you should have a list ofconsiderationsfor referral at all times and seek the appropriate Compliance, HR,Legal and H&Sadvice to ensure that you comply with UK Government, HSE,ICO&FCAregulations.

Throughout this document are links to the current HSE,ICOand Government guidancewhich is constantly being updated as things change. These should always be referredto as well as the FCA’s latest information for firmswhich is updated.

The FCApublished guidance on the handling of complaints, product value and thosein temporary financialdifficultywhich should also be taken into consideration whenreviewing who must be able to fulfil their role in full.

The FCAhas also confirmed it will allow individuals to carry over CPD for 1year inexceptional circumstances because of Covid-19but does expect individuals to stay upto date with Covid-19regulatorydevelopments during this time.

ConsultAs an employer you have a duty to engage with your staff on health and safety bylistening and talking to them about their work, how you will manage the risks fromCovid-19and their travel arrangements. Getting staff feedback will help make sure thechanges will work and ensure you can continue to operate your business safely duringthe outbreak.

Nobody knowsyourbusinessbetter than the people who work and manage theactivitiesin the workplace, however it is vitally important that you consult regularly

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with your employees when preparing risk assessmentsand guidance for return to work(involving them in your decision-making process you will show that you take their healthand safety seriously).

You should consider if any of your keyworkers need a letter from you to help withtheir childcare arrangements as things develop. The FCApublished guidance onidentifying keyworkers in March; “Akey financial worker fulfils a role which is necessaryfor the firm to continue to provide essential daily financial services to consumers, or toensure the continued functioning of markets.”

Youmust expect that some of yourstaffmay not be able to return to the officepart orfull time immediately due to childcare or transport issuesor the need to self-isolate.

AssessThe government has made it abundantly clear that firms must undertake a COVID-19workplace risk assessment to identify which staff should return to their office premisesand assesshow they will ensure safeworking. Refer to Governmentworking safelyand HSEworking safely guidelines and managing risks and risk assessment at work.First and foremost, employee safety is paramount.

Conducting this assessmentwith your staff will help to identify the vulnerable staff andthose who would have to travel by public transport, the staffwho aren’t able to returnfor childcare reasonsand the staff/roles that could benefit from returning to the officeenvironment. Thiswould help you, as a management team, to consider the optionsof flexible working practices, plan for potentially staggered start and end times andimplement the required changes you have determined for safeworking practices.

You should have evidence that you have conducted this riskassessmentand that itisperiodically and continuously reviewed.

It is important that you document your process for identifying and deciding whichstaff are to return to work. The Equality and Human Rights Commission has publishedCovid-19 guidance for employers on avoiding discrimination.

As a management team ask yourselves what is the current situation and why have youdecided to change the current situation? Some of the reasonsmaybe because of needfor additional resource to deal with complaints, accounts, security reasons or businessefficiency for example.

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Under the Health and Safety at Work Act 1974,the employer has a statutory duty ofcare to protect employees, contractors and any other persons who come into contactwith the company (including members of the public). This means the duty will extendto those hired by the company on a consultancy basis.

The government expects all organisationswith more than 50 employees to publishtheir risk assessment results.

Complying with and displaying documents published under government guidance suchas “StayingCovid-19secure in 2020” will show staff you have followed the guidance.

You may also need to assesswhether there is likely to be a continued reduction in theneed for certain roles once the lockdown has eased and indeed whether new roles areneeded and which employees could be re-trained or up-skilled. In particular given therenewed importance of technology and automation more remote-working may presentcost savings in terms of physical space aswell as a wider potential talent pool.

Of course for some employers, the challenge will be ensuring sufficient staffing giventhe possibility of higher absence levels due to further outbreaks or where staff areunable to work due to shielding or caring responsibilities.

Before restarting after this long closure variouschecks should be done on officebuildings which must be inspected for signs of deterioration or damage needing repair,also security installations should be checked (alarms,CCTV,sprinklers, fire doors andextinguishers). Any heavy plant equipment would also need to go through start-upchecks.

Water should be reopened slowly to avoid damaged pipes and minimising the riskoflegionella would need to be considered for water outlets that have not been used forweeks. ClaimsManagement companies or others operating fleets should check theirvehicles are road-legal, drivers should be confident about their skills and they will needto be trained on revised procedures, including how to work in compliance when atcustomer premises.

The Government’s guidance states that employers are only required to provide PPE(personal protective equipment) if that is normally required to protect against non-Covid-19 risks or in clinical settings.Workplaces should not necessarily encouragethe precautionary use of extra PPEto protect against coronavirus outside clinicalsettings or when responding to a suspected or confirmed case of coronavirus.Unlessthe employer is in a situation where the risk of coronavirus transmission is very high

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its risk assessment should reflect the fact that the role of PPEin providing additionalprotection is extremely limited.

There is no requirement for employers to provide clinical masks or other face coveringsfor employees, even where social distancing is not always possible.

The steps within this guidance document are not a risk assessment itself but aremeant to be used as an aide to consider when preparing to address the implicationsin the workplace of Covid-19.Considerationsshould include, but not be limited to, thefollowing:

Health and Safety policies, RiskAssessmentsand procedures (make sure thearrangements to manage Covid-19in the workplace are either integrated into your existingH&Spolicy or stipulated in a stand-alone policy). All applicable health & safety legislationand regulations remain fully in force, including, but not limited to the following: Healthand Safety at Work Act 1974,Management of Health & Safety at Work regulations1999,Workplace (Health, Safety &Welfare) Regulations 1992, Fire Safety RegulatoryReformOrder 2005 and HSERegulating occupational health and safety during thecoronavirusoutbreak.

Vulnerable and ExtremelyVulnerable Staff

• Some staff may be vulnerable or live with people who have pre-existing medicalconditions which render them more vulnerable to the dangers of coronavirusinfection

• Staffwho are considered extremely vulnerable or high-risk should not beexpected to attend for work in the workplace – where possible or appropriatethey should be furloughed or supported to work from home

• Make sure that communications go out that no member of staff should come towork if they are self-isolating or if they have COVID-19symptoms or if they feelunwell

• The safest roles on site should be offered to vulnerable staff if they cannot workfrom home

• The duty to make reasonable adjustments for pregnant employees or those withdisabilities continues to apply as normal

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Homeworking, Hot-desking and Equipment Sharing

• Which members of staff do you really need to get back into to the office andwhy?

• Which functions, individuals or tasks are critical to the organisationand can onlybe conducted from the office?

• Staff working together in workplace premises inevitably raises the risk of virustransmission.

• Hot desking and the sharing of equipment present hazardsthat raise the risk ofvirus transmission further

• Which teams in the businessneed to interact at the same times?

• Can you enable working from home as a first option?

• Do you have a homeworking policy?

• Have you conducted a homeworking risk assessment individually on all of yourhomeworkers?

• Have you provided training to your homeworkers on the risksassociatedwith homeworking?

• Are you maintaining regular documented contact with your homeworkers?Are they ok?

• What is the minimum number of people needed on site to operate requiredtasks safely and effectively?

Visiting Other Premisesor People Outside the OfficePremises

• Staffwho are required to travel for work and visit clients must be given safeaccess to the locations they are required to visit; how can you guarantee this?

• Make sure that your arrangements to manage Covid-19 risks outside of theworkplace are either integrated into your existing H&Spolicy or stipulated in astand-alone policy

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• Consider the provision of PPE;face mask, wipes, glasses,hand sanitiser/wash orgloves.

• Consider training on infection prevention and cleaning; encourage staff to followthe government’s suggested guidance on handwashingand hygiene.

• Request copies of the customer/supplier’s risk assessment for visitors attendingtheir workplace so they can be reviewed, discussed and concerns addressedbefore the visit.

• Carry out a Covid-19riskassessment. Consult your “on the road” staff abouttheir work, how you will manage the risks from Covid-19and their travelarrangements.

• Involve the individuals in your decision-making process; they are best placedto understand the risks,may know your customer/supplier’s premises and mayhave a view on how they can work safely

• If they must travel on public transport is this absolutely essential? Or can a videocall replace the transport

• Make sure all workers understand and are kept up to date with COVID-19relatedsafety procedures.

• Feeling apprehensive about attending a customer/supplier meeting or worriedabout an incident during such a meeting could increase stress/anxiety levels.

• Putting in place procedures to minimise person-to-person contact during visitsto other sites.

• Where workers are required to stay away from their home, centrally logging thestay and making sure any overnight accommodation meets social distancingguidelines.

• Minimise contact during payments and exchange of documentation, forexample, by using electronic payment methods and electronically signed andexchanged documents.

• Casesof Possible Infection; who at your customer’s firm will report anyincidences and to whom at your firm so this can be managed appropriately?

• Will your customers haveworkplace temperature testing that your staff may berequired to undertake?

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• Information Security and records;what data will your customer retain about yourmember of staff visiting their site and how will they ensure this is protected in linewith UK Data Protection regulations and GDPR?

• Communicating approaches and operational procedures to suppliers andcustomers to help their adoption and share experience.

• Are you confident you can keep your people safe?Is this an acceptable level of risk?

Infection Prevention,Cleaning and Staff Safety

• As the staff return to work the firm must ensure their safety by making premises“COVID”secure by StayingCovid-19secure in 2020 – unsafe workplacepremises raise the risks of virus transmission.

• It has been recommended to deep clean toilets, kitchen/canteen and otherspecific areasbefore reopening, and then implement a thorough regime ofsanitising. Particular attention should be given to desks, computers and phones.

• Can you increase the frequency of handwashing, surface cleaning & binemptying?

• Can you ensure the provision of cleaning products and review cleaningschedules to achieve this?

• Canyou increase ventilation in the workspace?

• PPE:Thegovernment suggests optional use of face coverings in enclosedspaces,where social distancing is not possible. However, the guidelinesemphasise this is optional and not required by law. Consider providingemployees with protective equipment, like gloves and masks and perhapsvisors,also share guidance on how to correctly place, wear and remove facemasks. If employees already wore PPEbefore the pandemic, employers mustensure that protective equipment meets the Covid-19requirements.

Workplace Social Distancing (Protectionand Distances)

• If working from home is not possible,workplaces should make every reasonableeffort to comply with the social distancing guidelines set out by the government

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(keeping people 2m apart wherever possible). Canyou comply with theseguidelines in full?

• Review all areasof work activity, look for contact points between employees andothers, possibly any members of the public or delivery drivers and consider / reassessif these can be managed within the current social distancing guidelines.Update your risk assessments to reflect any changes.

• Effective social distancing is a key element in reducing the transmission ofCovid-19.

• What adaptations to the premises are required to support social distancing?Physical barriers, changing the layout of workspaces, closing or limiting accessto communal spaces and limiting large events.

• Haveyou determined your maximum occupancy limits for all work areas/offices?

• Face to face workstations must be avoided.

• Introducing shift patterns will reduce the number of people present at one timeand allow staff to avoid peak travel times.

• Staggered breaks and meal breaksmay also need to be considered.

• Designating one-way areasand using additional entrances and exitswill aid tosupport your distancing measures.

• Where social distancing guidelines cannot be followed in full, in relation to aparticular activity, businesses should consider whether that activity needs tocontinue for the business to operate. If so, all mitigating actions must be takenwhere possible to reduce the risk of transmissionbetween staff.

• Finally, if people must work face-to-face for a sustained period with more thana small group of fixed partners, then you will need to assesswhether the activitycan safely go ahead.

• No one is obliged to work in an unsafework environment.

Higher RiskAreas of the Workplace

• Some areasof the workplace may present a higher risk than others – this mayinclude areas such as staff toilets, staff rooms and other restrooms

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• Canyou apply appropriate safety precautions to ensure that these higher-riskhigh traffic areas of the workplace are Covid secure?

• Holding essentialmeetings in well ventilated rooms or outdoors with appropriatesocial distancing in place – limit numbers to essentialmembers only and usephone/video conferencing,etc

• Printed handwashing instructions/posters and displaying throughout workplace,especially in toilets.

PremisesAccess and Travel

• Staffwho are required to attend for work must be given safe access to theworkplace

• Ensure that sufficient access points to the workplace are provided so that staffdo not congregate at entrances and exits – ensure that all access points havesupplies of sanitiser available.

• Use floor markings and signage at entrances and exits and introduce one-wayflow systems at entry and exit points where appropriate.

Physical and Mental Health of Staff and StaffingLevels

• If you do not have one of these already consider introducing a Mental HealthPolicy, Health &Wellbeing Champions, Mental Health First Aiders, an EmployeeAssistanceProgramme or Occupation Health Service.

• Good mental health management practices still apply during the pandemic

• Consider there may be low staffing hazards due to high rates of staff sickness orstaff having to self-isolate themselves at home or remain at home because theyare “shielded”.

• Have any of your staff been personally impacted by the lockdown or Covid-19?

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• Employee welfare and their ability to deliver at a time when they are also fearingfor their health or job is certainly an issue.

• Have you considered the psychological safety of your homeworkers and/orthose transitioning back to the office?

• Awareness and focus on the importance of mental health at times of uncertainty.

The government has published guidance on the mental health and wellbeingaspects of coronavirus.

Casesof Possible Infection On-site

• If the member of staff lives in a household where someone else is unwell withsymptoms of Covid-19then they must stay at home for 14days in line with thestay at home guidance and inform their line manager promptly.

• People becoming unwell while on-site or a symptomatic person using a site

• If a member of staff becomes unwell in the workplace with coronavirussymptoms (a new, continuous cough or a high temperature) they should besent home and advised to follow government advice to self-isolate for 7 daysfrom onset of symptoms; consider the actions that must be taken within theworkplace if this happens?

• Cleaning and disinfecting of work areasand public areas

• Cleaning staff training and disposable supplies

• Cleaning staff PPE

• Waste disposal

• If someone with Covid-19comes into a workplace, the workplace does notnecessarily have to close.Whether this is necessarywill depend on how quicklyany required deep cleaning can be done.Guidanceon cleaning an area aftersomeonewith suspectedCovid-19should be followed.

• The general duty to protect the health and safety of other employees meansthat employers will in most casesneed to keep an employee with suspectedCovid-19 infection away from the workplace until the risk has passed (whetherafter 7/14 days or on receipt of a negative test result).Employers should

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remind and instruct their staff to comply with the above advice and to notify theemployer if they need to self-isolate according to the guidance.

Workplace Temperature Testing

• Some organisationshave adopted temperature-screening processes at theirsites to seek to protect the health and safety of their collective workforce. Is thisabsolutely necessary for your firm?

• Consider the ICOGuidance onworkplace testing.

• Do you have individual consent to screen an employee’s temperature at theworkplace? This is required under best practice.

• The riskof direct discrimination/harassment should be appropriately mitigatedif screening is carried out consistently across all relevant workers to ensurecompliance with the EqualityAct 2010.

• Health and safety modifications should also be considered in respect of eachworker being screened.

• Under the EU general data protection regulation (GDPR),adata subject (i.e.theperson being screened)may consent to their data being processed only if thatconsent is ‘freely given’.

• A visitor to an organisation’spremises may be able to freely consent, it is unclearif an employee, worried about losing their job or wages if they refuse testing,could give valid consent in this situation.

• The GDPRotherwise provides legal bases under which personal health datacan be processed.Certain of these legal baseswill need to fulfil additional UK-specific requirements, as set out in the Data Protection Act 2018.

• Employers may likely rely on their obligation (under common law and UKhealth and safety legislation) to ensure the health, safety and welfare of theiremployees, which they could achieve by screening both employees and visitorsto their premises.

• If workplace temperature testing is adopted/implemented, it is important toupdate your policy relating to the processing of personal data to include this.

• The Information Commissioner’s Office (ICO)hasacknowledged that, to ensure

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the health and safety of their employees, employers may reasonably askindividuals if they have experienced COVID-19symptoms.

• Firms should minimise the amount of data collected by only asking fornecessary information and treating any data collected with appropriatesafeguards.The ICOsuggests minimising the collection of visitor information byasking them to consider government advice before visiting.

BusinessContinuity

• How are you managing the crisis and ongoing business continuity hazardscaused by Covid-19?

• Have the business continuity plans been reviewed by the necessary persons andupdated in line with what hashappened and what could come?

• Are the plans under constant review?

Information, Training& OngoingCommunication

• Communicate with your employees about what the new changesmay mean,ensuring that they fully understand and above all document and record alltraining and information going forward.

• Are your staff getting consistent, simple and clear business strategy andinformation messages to ensure their safety and wellbeing?

• Have you considered how in-house training can be conducted safely movingforwards?

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• Firms should meet regulatory requirements for CPDhowever, this can be carriedover for 1year but only in exceptional circumstances

• Have you properly informed and trained your staff on the risks associatedwithhomeworking or returning to the office environment?

• Include giving out information and instruction to staff.(Youmay want tohave an employee Covid-19Handbook or consider investing in your internalcommunications capability)

• Are leadership teams/supervisors/managers being briefed and kept up to date?

• Are the SeniorManagement Team reviewing all outward facing communications(website & social media platforms, etc) to ensure messages are consistent, clearand reflect the customer focused and socially aware values of the firm?

• Have communication strategies and plans been reviewed? How and how oftenemployees, clients and suppliers should be communicated to.

• Ongoing engagement with workers to monitor and understand any unforeseenimpacts of changes to working environments.

• How will you train staff and record that training (or induction) about the newworking arrangements?

Cyber Security

• Cyber-security threats often accompany a crisis, including computer viruses,phishing and scam emails and coronavirus related “ransomware”.

• The firm and individual employees are more reliant than ever on digitalcommunications and the internet, and with more staff working from home andusing a variety of digital devices, the need to ensure the security and function ofour digital systems is more important than ever.

• Have you reviewed your cyber security and surveillance infrastructure to ensurethat all reasonable protection is in place?

• Are you circulating warnings to managers and employees of cyber threats?

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• Ensure that any homeworking arrangements maintain standards of dataprotection and IT security.

• Ensure that existing cyber-security systems do not interfere with the availabilityof critical safety information and updates relating to Covid-19.

DecideThe SeniorManagement Team should decide which people it isabsolutelynecessary, for businessor personal needs, to return to the workplace.These are people who cannot carry out their entire role from home or are required atthe office for specific reason/s

The decisionsmade and rationale for these people to return to the workplace shouldbe recorded; which roles is this necessary for?who and why are they chosen to return?

If you decide to restart office activities the precautions raised by the assessment needto be taken and you need to be able to prove it through meticulous record-keepingaround changes to systems,procedures and processes.Documenting how you haveassessed the risks,designed the cleaning regime and informed their staff about thenew rules and conducted training may also help to avoid any potential claims in thefuture and may assistyou in regulatory investigations.

More importantly, you should put your employees and customers at the centre ofyour restart plan, considering people’s anxiety about returning to their workplace;Personify HRhas kindly provided a “Return to Work Flowchart” which can be found inour Covid-19hub and you should also refer to government guidance. You should alsounderstand that your customers’ needs will likely have changed tremendously.

Will you introduce workplace temperature testing?

Many firms are considering this although no official guidance has been issued on thissubject yet and the key legal issuesthat need to be considered; consent, compliancewith the EqualityAct 2010 & UKData protection law & GDPR.

Any monitoring of employees needs to be necessaryand proportionate, and in keepingwith their reasonable expectations. Handling this special category data requires youto protect it even more carefully and aswith all personal data handle it lawfully, fairly &transparently.

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Manage/Mitigate the RisksReduce the riskto the lowest reasonablypracticable level by taking preventativemeasures, in order of priority.

What changes do you need to make to mitigate all of the risks identified during yourfirm’s assessment process?

What information do you need to sharewith your staff?

• Sharing the results of your risk assessment on awebsite is expected forbusinesses of 50+employees.

• Display the HSE’s“StayingCOVID-19Secure in 2020” poster will show you arefollowing the government/HSE guidance

• Training:How will you train staffand record that training (or induction) aboutthe new working arrangements?

ReviewWhen staff are back in the office environment you should conduct a back to workinterview and training and make sure that staff are briefed and understand any newhealth and safety procedures as a result of Covid-19and what they must do.You shouldhave records of this. It is recommended that you issue a guide or handbook to staff andplan to continue meetings regularly to stay in touch.

Everyonehas been through and isstill going through a major event; it ismoreimportant than ever, as their employer, to keep in touch with yourstaff at this timeand maintain records of those conversations.

They may be caring for a friend or relative or have challenges with childcare. Youshould also regularly check they are familiar with the new health and safety proceduresin place to prevent the spread of Covid-19and check that they are aware of who tocontact if they have symptoms of, or believe they have been exposed to, Covid-19.

Mental Health. Discuss how employees are feeling and their stress levels; it is advisableto consider how pre-existing conditions could have been exacerbated by the outbreak.Consider if they will need further support and what your firm can offer to help.

Do you have a Mental Health Policy? Have you considered introducing Health &

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Wellbeing Champions? Wellbeing Champions are employees who volunteer to focuson improving the wellbeing of their fellow colleagues, as part of the company wellbeinginitiatives and are ambassadors of a company’s wellbeing strategy. It is universallyaccepted that worker wellbeing and productivity are intrinsically linked. Here are 5benefits of wellbeing champions in the workplace:

• Peer-based supportEngagement is an issue.Wellbeing champions can provide to be a valuablesource of confidential support and encouragement, particularly for those whoare disengaged with wellbeing initiativesor mistrustful of employer involvement.

• Promoting preventative healthcareIn the world of worker wellbeing the onus is shifting from reactive to preventativehealthcare (in the current climate this is now more than ever),wellbeingchampions can be armed with resourcesand time to encourage positivechange and help by servicing as first point of contact for employees and activelypromoting health campaigns and a firm’s health and wellbeing strategy. They arebest placed to be in the position to identify opportunities for early intervention.

• Creatingempathetic employeesWellbeing champions underline a company’s commitment to improvingthe wellbeing of its workforce, and act asvisible, constant reminders of thecommitment to the workplace.

• Dispelling fear of judgement (tackling the stigmas of mental health)HSEreported 15.4million working days were lost due to work-related stress,depression or anxiety in 2017/18,making it the number one employee healthissue faced by companies today, before Covid-19…

Workers may feel more comfortable speaking to someone outside of the linemanagement structure, such as a wellbeing champion, who is trained in mentalhealth first aid. Although not medically trained to deal with such issue, thesechampions can be trained to spot the signs of ill mental health in colleagues andsignpost them to the most appropriate avenue of help and support.

• Clarity on prevalent issuesIf your firm’s strategy is not based on or reflective of employee need andexpectation, it may well become redundant.

As wellbeing champions are peers, they have a greater understanding of theissuesthat are prevalent in the workplace/homeworking place, and the topareas for concern. By opening lines of communication between wellbeing

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champions and your SeniorManagement Team, direct feedback on the wantsand needs of employees can be offered on a regular basis,which will keepwellbeing at the forefront of decisionmakers’minds.

Whether you have 5 or 500 employees, it is important that you monitor new and revisedprocesses and activities to ensure that:

• Revised arrangements, working policies, risk assessments and practices arefunctioning as intended - it is essential to capture any comments and feedback.

• Ensure employees are adhering to these and, more importantly, that theyunderstand the importance of these.

• Take note of areas that may not be working so well.

• Engage with employees to assistwith working out what needs to change andwhat can be done better - in some casescertain practices may not be possible.

• Employees and managers should be trained in the steps that may need to betaken if the revised rules to maintain distancing are not being followed.

• Audits and reviews of your firm’s operation should be continually assessed toensure that all areas are undertaking operations as required and that there areno apparent moves away from the current procedures.

• Check and inspect workplaces regularly.

• Review training needs, policies and practices as required. Feedback to thenecessary areas of the firm.

• Revise,amend and publish changes and amendments to training, policies andpractices internally (in the workspace or intranet) and externally on website/social media.

• Record all changes as part of the process and ensure action is taken to addressthese, particularly when a concern is raised.

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The risk assessment you carried out for your business’sreturn to the office shouldbe periodically and continuouslyreviewed and the results recorded soyou haveevidence of this.

CommunicateHow well are you communicating your ongoing response to the crisis?

Have you considered investing in your internal communications and trainingcapabilities?

Having quick and easymethods of communication to give information or receivefeedback is of vital importance because of the changing nature of the world we findourselves in. Agree communication schedules with staff and be inclusive.

Consider how you will maintain this communication network, continually engage withstaff to ensure that you continue to keep your staff working safely at all times and aremeeting regulatory requirements to treat customers fairly and within their best interestswherever they are.

Creating a culture in the current climate where individuals feel comfortable to talk isvitally important to your firm’s approach to communication and will contribute to theongoing sustainability and reputation of your firm.

Should your businesshave an employee Covid-19 Handbook?

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Where canIobtainmore information?Links to the guidance referred to throughout the document can be found here:

FCACoronavirus (Covid-19):Information for firms

www.fca.org.uk/firms/information-firms-coronavirus-covid-19-response

FCAFirm handling of complaints during coronaviruswww.fca.org.uk/firms/firm-handling-complaints-during-coronavirus

FCAProduct value and coronavirus:draft guidance for insurance firms

FCAKeyworkers in financial serviceswww.fca.org.uk/firms/key-workers-financial-services

FCACoronavirus and customers in temporary financial difficulty: guidance for insuranceand premium finance firms

FCAAllowing individuals to carry over Continuing ProfessionalDevelopment (CPD)because of coronavirus

FCACovid-19 regulatory developmentswww.fca.org.uk/coronavirus

HSERegulating occupational health and safety during the coronavirus outbreak

HSEProtect Home Workerswww.hse.gov.uk/toolbox/workers/home.htm

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ICO– Guide to the General Data Protection regulation (GDPR)

HSEFirst Aid Qualifications and Coverwww.hse.gov.uk/news/first-aid-certificate-coronavirus.htm

HSEManaging risks and risk assessment at workwww.hse.gov.uk/simple-health-safety/risk/index.htm#

HSEWorking safely during the coronavirus outbreakwww.hse.gov.uk/news/working-safely-during-coronavirus-outbreak.htm#

HSWA 1974www.hse.gov.uk/legislation/hswa.htm

Guidance - Staying at home and away from others (socialdistancing)www.gov.uk/government/publications/staying-alert-and-safe-social-distancing

Guidance - Coronavirus outbreak FAQs:what you can and cannot do

Guidance for employers and businesses on coronavirus (COVID-19)www.gov.uk/coronavirus/business-support

Working Safelywww.gov.uk/guidance/working-safely-during-coronavirus-covid-19

Working safely during coronavirus (COVID-19)inoffices and contact centres

Staying COVID-19Secure in 2020(Posterto display in your workplace to show you have followed the guidance.)

Guidance for the public on the mental health and wellbeing aspects of coronavirus(COVID-19)

ICOWorkplace testing – guidance for employers

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The Data Protection Act

www.gov.uk/data-protection

Equality Act 2010www.gov.uk/guidance/equality-act-2010-guidance

Equality and Human RightsCommission/Coronavirus (Covid19)Guidance for Employershttps://www.equalityhumanrights.com/en/advice-and-guidance/coronavirus-covid-19-guidance-employers

Health and safety at Work Act 1974www.hse.gov.uk/legislation/hswa.htm

Management of Health and Safety at Work Regulations 1999www.hse.gov.uk/pubns/hsc13.pdf

Workplace health, safety and welfare.Workplace (Health,Safety and Welfare)Regulations 1992.Approved Code of Practice and guidancewww.hse.gov.uk/pubns/books/l24.htm

The Regulatory Reform (Fire Safety) Order 2005 (FSO)www.hse.gov.uk/construction/safetytopics/generalfire.htm

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DisclaimerThis information is to be used as general guidance only. Government advice is changingall the time. The particular risks and hazards relating to your organisation,work activitiesand environment may differ significantly from those suggested here. You are thereforeadvised to evaluate its contents thoroughly and adapt to suit the requirements of eachindividual situation.Check local policies, arrangements and guidance from relevanttrade and professional bodies. You should also seek professional H&S,Legal, or HRadvice where appropriate.

Avensure Ltd

4th Floor, South Central, 11 Peter St,Manchester, M2 5QR0330 100 8705 www.avensure.com

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AssessDecide Mitigate

Monitor &Gain Feedback

Document

Consult

Keep upto date

KeepReviewing

Inform,Communicate

& UpdateTrain

Avensure Ltd 2020