Develop corporate information
Trading name of Ampersand Consulting Ltd
Registered in England No. 07676726
Registered office: 19-21 Great Tower Street, London, United Kingdom, EC3R 5AR
VAT nr: GB 140 6933 22
This Privacy Notice was last updated: 7 September 2020.
The Develop Group (”We”) are committed to protecting and respecting your privacy.
Our Group means our subsidiaries, our ultimate holding company and its subsidiaries, our associated companies as defined in section 1159 of the UK Companies Act 2006 (our Group).
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC) The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Your new rights under the GDPR are set out in this notice but will only apply once the GDPR becomes law on 25th May 2018.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purposes of data protection legislation in force from time to time the data controller is The Develop Group of 19-21 Great Tower Street, London EC3R 5AR, United Kingdom.
Our nominated representative OR Data Protection Officer is Barbara Hudecova.
Who we are and what we do:
We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003 (our business). We also provide the following other services; consultancy. We collect the personal data of the following types of people to allow us to undertake our business;
• Prospective and placed candidates for permanent or temporary roles:
• Prospective and live client contacts:
• Supplier contacts to support our services;
• Employees, consultants, temporary workers;
We collect information about you to carry out our core business and ancillary activities.
Information you give to us or we collect about you.
This is information about you that you give us by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, Job Boards and when you report a problem with our site.
The information you give us or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.
Information we collect about you when you visit our website.
With regard to each of your visits to our site we will automatically collect the following information:
technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version.
information about your visit, including [the full Uniform Resource Locators (URL),] [clickstream to, through and from our site (including date and time),] [products you viewed or searched for’] [page response times,] [download errors,] [length of visits to certain pages,] [page interaction information (such as scrolling, clicks, and mouse-overs),] [methods used to browse away from the page,] and any phone number used to call our customer service number.
Information we obtain from other sources.
This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, personal recommendations, and events.
We are working closely with third parties including companies within our Group, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies, and professional advisors. We may receive information about you from them for the purposes of our recruitment services and ancillary support services, such as Names, address, email ID, phone numbers, and career interests.
Purposes of the processing and the legal basis for the processing
We use information held about you in the following ways:
To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation.
To provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with or enquired about.
The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career and to supporting businesses’ resourcing needs and strategies.
Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data.
We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
We will rely on legal obligation if we are legally requires to hold information on to you to fulfil our legal obligations.
We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. Examples of when consent may be the lawful basis for processing include permission to introduce you to a client (if you are a candidate).
Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data is described below:
As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.
To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts.
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Other Uses we will make of your data:
• Use of our website;
• to notify you about changes to our service;
• to ensure that content from our site is presented in the most effective manner for you and for your computer.
We will use this information:
• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• to allow you to participate in interactive features of our service, when you choose to do so;
• as part of our efforts to keep our site safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
We do not undertake automated decision making or profiling. We do use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process. if automated decision making or profiling is used then provide information about how decisions are made, the significance and the consequences.
Disclosure of your information inside and outside of the EEA
We will share your personal information with:
Any member of our group both in the EEA and outside of the EEA.
Selected third parties including:
• clients for the purpose of introducing candidates to them;
• candidates for the purpose of arranging interviews and engagements;
• clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
• subcontractors including email marketing specialists, event organisers, payment and other financial service provider
• advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
• analytics and search engine providers that assist us in the improvement and optimisation of our site;
• credit reference agencies, our insurance broker, compliance partners and other sub-contractors for assessing your suitability for a role where this is a condition of us entering into a contract with you.
We will disclose your personal information to third parties:
• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If The Develop Group or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
The lawful basis for the third-party processing will include:
• Their own legitimate business interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
• satisfaction of their contractual obligations to us as our data processor;
• for the purpose of a contract in place or in contemplation;
• to fulfil their legal obligations.
Where we store and process your personal data
The data that we collect from you may/will be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of our recruitment services. It may/will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. The Develop Group will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted [using SSL technology]. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Retention of your data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest in maintaining.
We do the following to try to ensure our data is accurate:
• prior to making an introduction we check that we have accurate information about you
• we keep in touch with you so you can let us know of changes to your personal data
We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data includes:
• the nature of the personal data;
• its perceived accuracy;
• our legal obligations;
• whether an interview or placement has been arranged; and
• our recruitment expertise and knowledge of the industry by country, sector and job role.
We may archive part or all of your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may pseudonymise parts of your data, particularly following a request for suppression or deletion of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.
For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
Our current retention notice is available upon request.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes.
You can exercise your right to accept or prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The GDPR provides you with the following rights. To:
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party in certain formats, if practicable.
• Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/
Access to information
The Data Protection Act 1998 and the GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete.
Your right of access can be exercised in accordance with the Act (and the GDPR once it is in force).
A subject access request should be submitted to email@example.com. No fee will apply once the GDPR comes into force.
Changes to our privacy notice
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to firstname.lastname@example.org.
What are cookies?
A cookie is a very small text file containing a piece of information that’s placed on an internet user’s computer. It’s generated by a web page server and can be used by that server whenever the user visits the site. You could think of it as a sort of identification card, which tells a web site that a user’s returned. The Develop Group uses them to help us see how visitors use our website, to help make the experience as easy as possible.
Cookies can’t harm your computer, and we don’t store any personally identifiable information about you on any of our cookies.
What cookies do we use?
‘Google Analytics’ collects anonymous statistical data about how you use The Develop Group’s website. The information is used to track the performance of our website and help us improve the service we offer.
More information can be found here: Google’s Policies & Privacy
By using The Develop Group’s website you consent to ‘Google Analytics’ processing data about you, in the ways set out above.
Customer Service Policy
The Develop Group Customer Service Policy Statement
At Develop. we endeavour to provide you with the best possible service at all times. If you would like to make any comments, suggestions, raise a query or make a complaint about the service you have received, please contact us, our contact details are set out below. We will respond to your query within 5 working days.
This policy will be kept up to date, to reflect changes in the nature and size of the business. To ensure this, the policy and its effectiveness will be reviewed annually.
All recruitment consultants will be trained in customer service standards; will exhibit customer friendly service skills; and be knowledgeable, professional and courteous in meeting the needs of our customers.
We develop. will return all phone calls and emails received from clients and registered candidates and applications in respect of specific vacancies within agreed timescales. Where we are unable to meet this agreement, we will inform you of this as soon as possible and agree a new deadline.
As part of our commitment to upholding professional standards, we will review our policies annually to ensure that they continue to meet business needs and the Recruitment and Employment Confederation’s Code of Professional Practice; and that they are consistently applied to all our customers.
Develop. seeks fair, just and prompt solutions when possible to any complaints and appeals. A complaints process is in place for any disputes; copies are available from our offices or on www.rbwconsulting.com.
Access to Information
We comply fully with the provisions of the Data Protection Act 1998 and GDPR2018. Any personal or confidential information held by us about a client or work seeker is fully accessible to that person or body for review or editing by contacting one of the Partners
Wherever possible, without compromising our legal requirements and professional standards we strive to reduce the burden of unnecessary paperwork.
How to Contact Us
Address: 19-21 Great Tower Street, London, EC3R 5AR, United Kingdom
Tel: +44 (0)2077330430
The Develop Group is committed to providing a high level service to our customers. If you do not receive satisfaction from us we need you to tell us about it. This will help us to improve our standards.
If you have a complaint, please contact Barbara Hudecova by phone (+44 (0)2077330430) in the first instance so that we can try to resolve your complaint informally.
At this stage, if you are not satisfied please contact Kevin Hammond, Director. You can write to him at: The Develop Group, 19-21 Great Tower Street, London, EC3R 5AR, United Kingdom.
1. We will acknowledge your complaint and ask you to confirm or explain the details set out. We will also let you know the name of the person who will be dealing with your complaint. You can expect to receive our acknowledgement within 5 working days of us receiving your complaint. This may be sent by letter or electronic mail.
2. We will record your complaint in our central register within a day of having received it.
3. We will acknowledge your reply to our acknowledgment and confirm what will happen next within 5 working days of your reply.
4. We will then start to investigate your complaint. This will normally involve the following steps;
• We may ask the member of staff who dealt with you to reply to your complaint within 5 working days of our request;
• We will then examine the member of staff’s reply and the information you have provided for us. If necessary, we may ask you to speak to them. This will take up to 4 working days from receiving their reply.
5. Kevin Hammond will then invite you to meet him to discuss and hopefully resolve your complaint. He will do this within 5 working days of the end of our investigation.
6. Within 2 working days of the meeting Kevin Hammond will write to you to confirm what took place and any solutions agreed with you.
If you do not want a meeting or it is not possible, Kevin Hammond will send you a detailed reply to your complaint. This will include suggestions for resolving the matter. He will do this within 5 working days of completing our investigation.
If we have to change any of the time scales above, we will let you know and explain why.
NOTE: In any event, we will comply with any statutory procedures that may relate to your complaint.
Equal Opportunities & Diversity
1.1 The Develop Group embraces diversity and will seek to promote the benefits of diversity in all of our business activities. We will seek to develop a business culture that reflects that belief. We will seek to widen the media in which we recruit to ensure as diverse an employee and candidate base as possible. We will strive to make sure that our clients meet their own diversity targets.
The Develop Group is committed to diversity and will promote diversity for all employees, workers and applicants and shall adhere to such a policy at all times. We will review on an on-going basis all aspects of recruitment to avoid unlawful or undesirable discrimination. The Develop Group will treat everyone equally irrespective of sex, sexual orientation, gender reassignment, marital or civil partnership status, age, disability, colour, race, nationality, ethnic or national origin, religion or belief, political beliefs or membership or non-membership of a Trade Union or spent convictions, and places an obligation upon all staff to respect and act in accordance with the policy.
The Develop Group is committed to providing training for its entire staff in equal opportunities practice. The Develop Group shall avoid stipulating any unnecessary requirements which would exclude a higher proportion of a particular gender, sexual orientation, age, religion or racial group or which would exclude disabled job applicants; and will avoid prescribing any requirements as to marital or civil partnership status.
1.2 The Develop Group shall not discriminate unlawfully when deciding which candidate/temporary worker is submitted for a vacancy or assignment, or in any terms of employment or terms of engagement for temporary workers. The Develop Group will ensure that each candidate is assessed only in accordance with the candidate’s merits, qualifications and abilities to perform the relevant duties required by the particular vacancy.
1.3 The Develop Group not accept instructions from clients that indicate an intention to discriminate unlawfully.
Unlawful discrimination occurs in the following circumstances:
2.1 Direct discrimination
Direct discrimination occurs where one individual treats or would treat another individual less favourably because of sex, sexual orientation, gender reassignment, marital or civil partnership, age, disability, colour, race, nationality, ethnic or national origin, religion or belief, political beliefs (“the protected categories”).
It is unlawful for a recruitment consultancy to discriminate against a person on the grounds of a protected category:
• in the terms on which the recruitment consultancy offers to provide any of its services;
• by refusing or deliberately omitting to provide any of its services;
• in the way it provides any of its services.
Direct discrimination would also occur if a recruitment consultancy accepted and acted upon a job registration from an employer which states that certain persons are unacceptable due to a protected category, unless one of the exceptions applies, for instance, the job demands a genuine occupational requirement or in the case of age, the discrimination can be lawfully justified.
2.2 Indirect Discrimination
Indirect discrimination occurs where an agency or employer applies a provision, criterion or practice generally, which disadvantages a minority group in the community on the basis of a protected category.
Indirect discrimination would also occur if a recruitment consultant accepted and acted upon an indirectly discriminatory instruction from an employer.
If the vacancy requires characteristics which amount to a genuine occupational requirement or the instruction is lawfully discriminatory due to a statutory exception or objective justification, The Develop Group will not deal further with the vacancy unless the client provides written confirmation of such genuine occupational requirement, exception or justification.
2.3 Disabled Persons
Direct discrimination against a person occurs where, a person is treated less favourably because of disability, either their own disability or because someone they are associated with has a disability.
Indirect discriminations occurs when a practice, criterion or provision which cannot be objectively justified is applied to everyone but results in person with a disability being placed at a disadvantage.
Disability arising from discrimination occurs when a person is treated unfavourably because of something arising in connection with their disability.
2.3.2 Duty to make reasonable adjustments and to provide auxiliary aids and services
This is a similar protection to indirect discrimination in the other protected categories.
Where a provision, criterion or practice applied by or on behalf of an employer, or any physical feature of the employer’s premises, places a disabled person at a substantial disadvantage in comparison with persons who are not disabled, it will be the duty of an employer to take such steps as are reasonable, in all the circumstances of the case, to remove the provision, criterion, practice or physical feature.
Agencies must take reasonable steps to provide auxiliary aids or services if this would make it easier for the disabled person to use their services. For instance, an appropriate auxiliary aid or service can include the provision of information on audiotape or provision of a sign language interpreter.
The Develop Group will not discriminate against a disabled person on the grounds of disability.
• in the arrangements i.e. application form, interview or arrangements for selection for determining to whom a job should be offered; or
• in the terms on which employment or engagement of temporary workers is offered; or
• by refusing to offer, or deliberately not offering the disabled person a job for reasons connected with their disability; or
• in the opportunities afforded to the person for receiving any benefit, or by refusing to afford, or deliberately not affording him or her any such opportunity; or
• by subjecting him or her to any other detriment (detriment will include refusal of training or transfer, demotion, reduction of wage, or harassment).
The Develop Group will accordingly make career opportunities available to all people with disabilities and every practical effort will be made to provide for the needs of staff, candidates and clients.
Wherever possible The Develop Group will make reasonable adjustments to hallways, passages and doors in order to provide and improve means of access for disabled employees and workers. However, this may not always be feasible, due to circumstances creating such difficulties as to render such adjustments as being beyond what is reasonable in all the circumstances.
3. Age Discrimination
The Develop Group will not discriminate directly or indirectly, harass or victimise any person on the grounds of their age. We will encourage clients not to include any age criteria in job specifications and every attempt will be made to persuade clients to recruit on the basis of competence and skills and not age.
The Develop Group is committed to recruiting and retaining employees whose skills, experience, and attitude are suitable for the requirements of the various positions regardless of age.
No age requirements will be stated in any job advertisements on behalf of the company.
The Develop Group will request age as part of its recruitment process but such information will not be used as selection, training or promotion criteria or in any detrimental way and is only for compilation of personal data, which the company holds on all employees and workers and as part of its equal opportunities monitoring process.
4. Part-time Workers
This Diversity Policy also covers the treatment of those employees and workers who work on a part-time basis, The Develop Group recognises that it is an essential part of this policy that part time employees are treated on the same terms, with no detriment, as full time employees (albeit on a pro rata basis) in matters such as rates of pay, holiday entitlement, maternity leave, parental and domestic incident leave and access to our pension scheme. The Develop Group also recognises that part time employees must be treated the same as full time employees in relation to training and redundancy situations.
5. Harassment Policy
5.1 The Develop Group is committed to providing a work environment free from unlawful harassment on grounds of sex, sexual orientation, gender reassignment, marital or civil partnership status, age, disability, colour, race, nationality, ethnic or national origin, religion or belief, political beliefs or any other basis protected by legislation is unlawful and will not be tolerated by The Develop Group.
5.2 This policy prohibits unlawful harassment by any employee or worker of The Develop Group.
5. Examples of prohibited harassment are:
• 5.3.1 verbal or written conduct containing derogatory jokes or comments;
• 5.3.2 slurs or unwanted sexual advances;
• 5.3.3 visual conduct such as derogatory or sexually orientated posters;
• 5.3.4 photographs, cartoons, drawings or gestures which some may find offensive;
• 5.3.5 physical conduct such as assault, unwanted touching, or any interference because of sex, race or any other protected category basis;
• 5.3.6 Threats and demands to submit to sexual requests as a condition of continued employment or to avoid some other loss, and offers of employment benefits in return for sexual favours;
• 5.3.7 Retaliation for having reported or threatened to report harassment.
5.4 If you believe that you have been unlawfully harassed, you should make an immediate report to Joey Tait followed by a written complaint as soon as possible after the incident. Your complaint should include:
• Details of the incident
• Name(s) of the individual(s) involved
• Name(s) of any witness(es)
5.5 The Develop Group will undertake a thorough investigation of the allegations. If it is concluded that unlawful harassment has occurred, remedial action will be taken.
5.6 Any employee(s) who The Develop Group finds to be responsible for unlawful harassment will be subject to the disciplinary procedure and any sanction may include termination. [A person who discriminates or harasses may be personally liable for payment of compensation to the person offended, in addition to any compensation payable by The Develop Group. There is no statutory cap on the amount of compensation which may be awarded in discrimination cases. Under the Criminal Justice Act 1994, harassment became a criminal offence, punishable by a fine of up to £5,000 and/or a prison term of up to 6 months. Under the Protection from Harassment Act 1997, the penalties for aggravated harassment are an unlimited fine and/or 5 years imprisonment.]
6. Gender Reassignment Policy
6.1 The Develop Group recognises that any employee or worker may wish to change their gender during the course of their employment with the Company.
6.2 The Develop Group will support any employee or worker through the reassignment.
6.3 The Develop Group will make every effort to try to protect an employee or worker who has undergone, is undergoing or intends to undergo gender reassignment, from discrimination or harassment within the workplace.
6.4 All employees and workers will be expected to comply with The Develop Group’s policy on harassment in the workplace. Any breach of such a policy will lead to the appropriate disciplinary sanction.
6.5 Where an employee is engaged in work where the gender change imposes genuine problems The Develop Group will make every effort to reassign the employee or worker to an alternative role in the Company, if so desired by the employee.
6.6 Any employee or worker suffering discrimination on the grounds of gender reassignment should make recourse to the Company’s grievance procedure.
5. Complaints and Monitoring Procedures
7.1 The Develop Group has in place procedures for monitoring compliance with this policy and for dealing with complaints of discrimination. These are available from Joey, Martin or Kevin and will be made available immediately upon request.
7.2 Any discrimination complaint will be investigated fully.
Anti-slavery & Human Trafficking
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, agents, contractors and suppliers. The Develop Group strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.
Modern Slavery and Human Trafficking
Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.
We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:
• We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.
• The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
• We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
• We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked based approach, we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.
• Consistent with our risk-based approach we may require:
• employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct
• Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code
• As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct.
• If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.