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Privacy and Cookie Policies

This website is published and managed by Phoenix Sustainable Investments Limited, it is committed to protecting the privacy of our users and customers. This privacy policy (“Privacy Policy”) is intended to inform you on how we gather, define, and utilise your Information (as defined below).

Data Protection

Data Protection Policy

1. Interpretation

 

1.1 Definitions:

 

Company: Phoenix Sustainable Investments Limited and any of its subsidiaries.

 

Company Personnel: all employees, workers, contractors, agency workers, consultants, directors, members and others.

 

Consent: agreement which must be freely given, specific, informed and be an unambiguous indication of the Data Subject’s wishes by which they, by a statement or by a clear positive action, signify agreement to the Processing of Personal Data relating to them.

 

Controller: the person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in line with the UK GDPR. We are the Controller of all Personal Data relating to our Company Personnel and Personal Data used in our business for our own commercial purposes.

 

Criminal Convictions Data: means personal data relating to criminal convictions and offences and includes personal data relating to criminal allegations and proceedings. 

 

Data Subject: a living, identified or identifiable individual about whom we hold Personal Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data.

 

Data Privacy Impact Assessment (DPIA): tools and assessments used to identify and reduce risks of a data processing activity. DPIA can be carried out as part of Privacy by Design and should be conducted for all major system or business change programmes involving the Processing of Personal Data.

 

Data Protection Officer (DPO): the person required to be appointed in specific circumstances under the UK GDPR. Where a mandatory DPO has not been appointed, this term means a data protection manager or other voluntary appointment of a DPO or refers to the Company data privacy team with responsibility for data protection compliance.

 

Explicit Consent: consent which requires a very clear and specific statement (that is, not just action).

 

UK GDPR: the retained EU law version of the General Data Protection Regulation ((EU) 2016/679). Personal Data is subject to the legal safeguards specified in the UK GDPR and the Data Protection Act 2018.

 

Personal Data: any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data includes Special Categories of Personal Data and Pseudonymised.

 

Personal Data: but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person’s actions or behaviour. 

 

Personal Data Breach: any act or omission that compromises the security, confidentiality, integrity or availability of Personal Data or the physical, technical, administrative or organisational safeguards that we or our third-party service providers put in place to protect it. The loss, or unauthorised access, disclosure or acquisition, of Personal Data is a Personal Data Breach.

 

Privacy by Design: implementing appropriate technical and organisational measures in an effective manner to ensure compliance with the UK GDPR.

 

Privacy Guidelines: the Company privacy and UK GDPR related guidelines provided to assist in interpreting and implementing this Data Protection Policy.

 

Privacy Notices (also referred to as Fair Processing Notices) or Privacy Policies: separate notices setting out information that may be provided to Data Subjects when the Company collects information about them. These notices may take the form of general privacy statements applicable to a specific group of individuals (for example, employee privacy notices or the website privacy policy) or they may be stand-alone, one-time privacy statements covering Processing related to a specific purpose.

 

Processing or Process: any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.

 

Pseudonymisation or Pseudonymised: replacing information that directly or indirectly identifies an individual with one or more artificial identifiers or pseudonyms so that the person, to whom the data relates, cannot be identified without the use of additional information which is meant to be kept separately and secure.

 

Related Policies: the Company’s policies, operating procedures or processes related to this Data Protection Policy and designed to protect Personal Data.

 

Special Categories of Personal Data: information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data. 

 

2. Introduction

This Data Protection Policy sets out how Phoenix Sustainable Investments Limited and all of its subsidiaries (“we”, “our”, “us”, “the Company”) handle the Personal Data of our customers, suppliers, employees, workers and other third parties. 

 

This Data Protection Policy applies to all Personal Data we Process regardless of the media on which that data is stored or whether it relates to past or present employees, workers, customers, clients or supplier contacts, shareholders, website users or any other Data Subject. 

 

This Data Protection Policy applies to all Company Personnel (“you”, “your”). You must read, understand and comply with this Data Protection Policy when Processing Personal Data on our behalf and attend training on its requirements. This Data Protection Policy sets out what we expect from you for the Company to comply with applicable law. Your compliance with this Data Protection Policy is mandatory. Related Policies and Privacy Guidelines are available to help you interpret and act in accordance with this Data Protection Policy. You must also comply with all such Related Policies and Privacy Guidelines. Any breach of this Data Protection Policy may result in disciplinary action. 

 

Where you have a specific responsibility in connection with Processing such as capturing Consent, reporting a Personal Data Breach, conducting a DPIA as referenced in this Data Protection Policy or otherwise then you must comply with the Related Policies and Privacy Guidelines.  

 

This Data Protection Policy (together with Related Policies and Privacy Guidelines) is an internal document and cannot be shared with third parties, clients or regulators without prior authorisation from the DPO.

 

3. Scope

We recognise that the correct and lawful treatment of Personal Data will maintain confidence in the organisation and will provide for successful business operations. Protecting the confidentiality and integrity of Personal Data is a critical responsibility that we take seriously at all times. The Company is exposed to potential fines of up to £17.5 million or 4% of total worldwide annual turnover, whichever is higher and depending on the breach, for failure to comply with the provisions of the UK GDPR.

 

All departments are responsible for ensuring all Company Personnel comply with this Data Protection Policy and need to implement appropriate practices, processes, controls and training to ensure that compliance. 

 

The DPO is responsible for overseeing this Data Protection Policy and, as applicable, developing Related Policies and Privacy Guidelines. We have assessed and do not believe that a mandatory DPO is required and the Company’s DPO is voluntary. That post is held by Helen Hick, HR Director, email helen.hick@phoenix-sus.co.uk

 

Please contact the DPO with any questions about the operation of this Data Protection Policy or the UK GDPR or if you have any concerns that this Data Protection Policy is not being or has not been followed. In particular, you must always contact the DPO in the following circumstances: 

 

a) if you are unsure of the lawful basis which you are relying on to process Personal

b) Data (including the legitimate interests used by the Company) (see paragraph 5.1); 

c) if you need to rely on Consent and/or need to capture Explicit Consent (see paragraph 6);

d) if you need to draft Privacy Notices (see paragraph 7); 

e) if you are unsure about the retention period for the Personal Data being Processed (see paragraph 11);

f) if you are unsure about what security or other measures you need to implement to protect Personal Data (see paragraph 12.1);

g) if there has been a Personal Data Breach (paragraph 13);

h) if you are unsure on what basis to transfer Personal Data outside the UK (see paragraph 14);

i) if you need any assistance dealing with any rights invoked by a Data Subject (see paragraph 15); 

j) whenever you are engaging in a significant new, or change in, Processing activity which is likely to require a DPIA (see paragraph 19) or plan to use Personal Data for purposes other than what it was collected for; 

k) if you need help complying with applicable law when carrying out direct marketing activities (see paragraph 20); or

l) if you need help with any contracts or other areas in relation to sharing Personal Data with third parties (including our vendors) (see paragraph 21).

 

4. Personal data protection principles

We adhere to the principles relating to Processing of Personal Data set out in the UK GDPR which require Personal Data to be:

 

a) Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency); 

b) collected only for specified, explicit and legitimate purposes (Purpose Limitation);

c) adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation); 

d) accurate and where necessary kept up to date (Accuracy);

e) not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation);

f) Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality);

g) not transferred to another country without appropriate safeguards being in place (Transfer Limitation); and

h) made available to Data Subjects and allow Data Subjects to exercise certain rights in relation to their Personal Data (Data Subject’s Rights and Requests).

 

We are responsible for and must be able to demonstrate compliance with the data protection principles listed above (Accountability).

 

5. Lawfulness, fairness, transparency

 

5.1 Lawfulness and fairness

Personal data must be Processed lawfully, fairly and in a transparent manner in relation to the Data Subject.

 

You may only collect, Process and share Personal Data fairly and lawfully and for specified purposes. The UK GDPR restricts our actions regarding Personal Data to specified lawful purposes. These restrictions are not intended to prevent Processing but ensure that we Process Personal Data fairly and without adversely affecting the Data Subject. 

 

The UK GDPR allows Processing for specific purposes, some of which are set out below:

 

a) the Data Subject has given his or her Consent;

b) the Processing is necessary for the performance of a contract with the Data Subject;

c) to meet our legal compliance obligations; 

d) to protect the Data Subject’s vital interests;

e) to pursue our legitimate interests for purposes where they are not overridden because the Processing prejudices the interests or fundamental rights and freedoms of Data Subjects. The purposes for which we process Personal Data for legitimate interests need to be set out in applicable Privacy Notices.

 

You must identify and document the legal ground being relied on for each Processing activity.

 

6. Consent

A Controller must only process Personal Data on the basis of one or more of the lawful bases set out in the UK GDPR, which include Consent.

 

A Data Subject consents to Processing of their Personal Data if they indicate agreement clearly either by a statement or positive action to the Processing. Consent requires affirmative action so silence, pre-ticked boxes or inactivity are unlikely to be sufficient. If Consent is given in a document which deals with other matters, then the Consent must be kept separate from those other matters. 

 

Data Subjects must be easily able to withdraw Consent to Processing at any time and withdrawal must be promptly honoured. Consent may need to be refreshed if you intend to Process Personal Data for a different and incompatible purpose which was not disclosed when the Data Subject first consented. 

 

When processing Special Category Data or Criminal Convictions Data, we will usually rely on a legal basis for processing other than Explicit Consent or Consent if possible. Where Explicit Consent is relied on, you must issue a Privacy Notice to the Data Subject to capture Explicit Consent.  

 

You will need to evidence Consent captured and keep records of all Consents in accordance with Related Policies and Privacy Guidelines so that the Company can demonstrate compliance with Consent requirements.

 

7. Transparency (notifying Data Subjects)

The UK GDPR requires Controllers to provide detailed, specific information to Data Subjects depending on whether the information was collected directly from Data Subjects or from elsewhere. The information must be provided through appropriate Privacy Notices which must be concise, transparent, intelligible, easily accessible, and in clear and plain language so that a Data Subject can easily understand them.

 

Whenever we collect Personal Data directly from Data Subjects, including for human resources or employment purposes, we must provide the Data Subject with all the information required by the UK GDPR including the identity of the Controller and DPO, how and why we will use, Process, disclose, protect and retain that Personal Data through a Privacy Notice which must be presented when the Data Subject first provides the Personal Data. 

 

When Personal Data is collected indirectly (for example, from a third party or publicly available source), we must provide the Data Subject with all the information required by the UK GDPR as soon as possible after collecting or receiving the data. We must also check that the Personal Data was collected by the third party in accordance with the UK GDPR and on a basis which contemplates our proposed Processing of that Personal Data. 

 

If you are collecting Personal Data from Data Subjects, directly or indirectly, then you must provide Data Subjects with a Privacy Notice in accordance with our Related Policies and Privacy Guidelines. 

 

8. Purpose limitation 

Personal Data must be collected only for specified, explicit and legitimate purposes. It must not be further Processed in any manner incompatible with those purposes. 

 

You cannot use Personal Data for new, different or incompatible purposes from that disclosed when it was first obtained unless you have informed the Data Subject of the new purposes and they have Consented where necessary.

 

9. Data minimisation

Personal Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed.

 

You may only Process Personal Data when performing your job duties requires it. You cannot Process Personal Data for any reason unrelated to your job duties. 

 

You may only collect Personal Data that you require for your job duties: do not collect excessive data. Ensure any Personal Data collected is adequate and relevant for the intended purposes.

 

You must ensure that when Personal Data is no longer needed for specified purposes, it is deleted or anonymised in accordance with the Company’s data retention guidelines. 

 

10. Accuracy

Personal Data must be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay when inaccurate.

 

You will ensure that the Personal Data we use and hold is accurate, complete, kept up to date and relevant to the purpose for which we collected it. You must check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards. You must take all reasonable steps to destroy or amend inaccurate or out-of-date Personal Data.

 

11. Storage limitation

Personal Data must not be kept in an identifiable form for longer than is necessary for the purposes for which the data is processed.

 

The Company will maintain retention policies and procedures to ensure Personal Data is deleted after a reasonable time for the purposes for which it was being held, unless a law requires that data to be kept for a minimum time. 

 

You must not keep Personal Data in a form which permits the identification of the Data Subject for longer than needed for the legitimate business purpose or purposes for which we originally collected it including for the purpose of satisfying any legal, accounting or reporting requirements. 

 

You will take all reasonable steps to destroy or erase from our systems all Personal Data that we no longer require in accordance with all the Company’s applicable records retention schedules and policies. This includes requiring third parties to delete that data where applicable. 

 

You will ensure Data Subjects are informed of the period for which data is stored and how that period is determined in any applicable Privacy Notice. 

 

12. Security integrity and confidentiality

 

12.1 Protecting Personal Data

Personal Data must be secured by appropriate technical and organisational measures against unauthorised or unlawful Processing, and against accidental loss, destruction or damage.

 

We will develop, implement and maintain safeguards appropriate to our size, scope and business, our available resources, the amount of Personal Data that we own or maintain on behalf of others and identified risks (including use of encryption and Pseudonymisation where applicable). We will regularly evaluate and test the effectiveness of those safeguards to ensure security of our Processing of Personal Data. You are responsible for protecting the Personal Data we hold. You must implement reasonable and appropriate security measures against unlawful or unauthorised Processing of Personal Data and against the accidental loss of, or damage to, Personal Data. You must exercise particular care in protecting Special Categories of Personal Data and Criminal Convictions Data from loss and unauthorised access, use or disclosure.

 

You must follow all procedures and technologies we put in place to maintain the security of all Personal Data from the point of collection to the point of destruction. You may only transfer Personal Data to third-party service providers who agree to comply with the required policies and procedures and who agree to put adequate measures in place, as requested.

 

You must maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as follows:

 

a) Confidentiality means that only people who have a need to know and are authorised to use the Personal Data can access it;

b) Integrity means that Personal Data is accurate and suitable for the purpose for which it is processed; and

c) Availability means that authorised users are able to access the Personal Data when they need it for authorised purposes. 

 

You must comply with and not attempt to circumvent the administrative, physical and technical safeguards we implement and maintain in accordance with the UK GDPR and relevant standards to protect Personal Data. 

 

13. Reporting a Personal Data Breach

The UK GDPR requires Controllers to notify any Personal Data Breach to the Information Commissioner and, in certain instances, the Data Subject. 

 

We have put in place procedures to deal with any suspected Personal Data Breach and will notify Data Subjects or any applicable regulator where we are legally required to do so.

 

If you know or suspect that a Personal Data Breach has occurred, do not attempt to investigate the matter yourself. Immediately contact the DPO. You should preserve all evidence relating to the potential Personal Data Breach. 

 

14. Transfer limitation 

The UK GDPR restricts data transfers to countries outside the UK to ensure that the level of data protection afforded to individuals by the UK GDPR is not undermined. You transfer Personal Data originating in one country across borders when you transmit, send, view or access that data in or to a different country. 

 

You may only transfer Personal Data outside the UK if one of the following conditions applies:

 

a) the UK has issued regulations confirming that the country to which we transfer the Personal Data ensures an adequate level of protection for the Data Subject’s rights and freedoms; 

b) appropriate safeguards are in place such as binding corporate rules (BCR), standard contractual clauses approved for use in the UK, an approved code of conduct or a certification mechanism, a copy of which can be obtained from the DPO;

c) the Data Subject has provided Explicit Consent to the proposed transfer after being informed of any potential risks; or

d) the transfer is necessary for one of the other reasons set out in the UK GDPR including the performance of a contract between us and the Data Subject, reasons of public interest, to establish, exercise or defend legal claims or to protect the vital interests of the Data Subject where the Data Subject is physically or legally incapable of giving Consent and, in some limited cases, for our legitimate interest.

 

15. Data Subject’s rights and requests

Data Subjects have rights when it comes to how we handle their Personal Data. These include rights to:

 

a) withdraw Consent to Processing at any time;

b) receive certain information about the Controller’s Processing activities;

c) request access to their Personal Data that we hold;

d) prevent our use of their Personal Data for direct marketing purposes; 

e) ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or Processed or to rectify inaccurate data or to complete incomplete data; 

f) restrict Processing in specific circumstances;

g) challenge Processing which has been justified on the basis of our legitimate interests or in the public interest;

h) request a copy of an agreement under which Personal Data is transferred outside of the UK; 

i) prevent Processing that is likely to cause damage or distress to the Data Subject or anyone else;

j) be notified of a Personal Data Breach which is likely to result in high risk to their rights and freedoms;

 

k) make a complaint to the supervisory authority; 

l) in limited circumstances, receive or ask for their Personal Data to be transferred to a third party in a structured, commonly used and machine-readable format.

 

You must verify the identity of an individual requesting data under any of the rights listed above (do not allow third parties to persuade you into disclosing Personal Data without proper authorisation). 

 

You must immediately forward any Data Subject request you receive to the DPO. 

 

16. Accountability

The Controller must implement appropriate technical and organisational measures in an effective manner, to ensure compliance with data protection principles. The Controller is responsible for, and must be able to demonstrate, compliance with the data protection principles. 

 

The Company must have adequate resources and controls in place to ensure and to document UK GDPR compliance including:

 

a) appointing a suitably qualified DPO (where necessary) and an executive accountable for data privacy; 

b) implementing Privacy by Design when Processing Personal Data and completing DPIAs where Processing presents a high risk to rights and freedoms of Data Subjects; 

c) integrating data protection into internal documents including this Data Protection Policy, Related Policies, Privacy Guidelines or Privacy Notices;

d) regularly training Company Personnel on the UK GDPR, this Data Protection Policy, Related Policies and Privacy Guidelines and data protection matters including, for example, Data Subject’s rights, Consent, legal basis, DPIA and Personal Data Breaches. The Company must maintain a record of training attendance by Company Personnel; and 

e) regularly testing the privacy measures implemented and conducting periodic reviews and audits to assess compliance, including using results of testing to demonstrate compliance improvement effort.

 

17. Record keeping

The UK GDPR requires us to keep full and accurate records of all our data Processing activities. 

 

You must keep and maintain accurate corporate records reflecting our Processing including records of Data Subjects’ Consents and procedures for obtaining Consents.

 

These records should include, at a minimum, the name and contact details of the Controller and the DPO, clear descriptions of the Personal Data types, Data Subject types, Processing activities, Processing purposes, third-party recipients of the Personal Data, Personal Data storage locations, Personal Data transfers, the Personal Data’s retention period and a description of the security measures in place. To create the records, data maps should be created which should include the detail set out above together with appropriate data flows. 

 

18. Training and audit

We are required to ensure all Company Personnel have undergone adequate training to enable them to comply with data privacy laws. We must also regularly test our systems and processes to assess compliance. 

 

You must undergo all mandatory data privacy related training and ensure your team undergo similar mandatory training.

 

You must regularly review all the systems and processes under your control to ensure they comply with this Data Protection Policy and check that adequate governance controls and resources are in place to ensure proper use and protection of Personal Data. 

19. Privacy by Design and Data Protection Impact Assessment (DPIA)

We are required to implement Privacy by Design measures when Processing Personal Data by implementing appropriate technical and organisational measures (like Pseudonymisation) in an effective manner, to ensure compliance with data privacy principles. 

 

You must assess what Privacy by Design measures can be implemented on all programmes, systems or processes that Process Personal Data by taking into account the following:

 

the state of the art;

the cost of implementation;

the nature, scope, context and purposes of Processing; and

the risks of varying likelihood and severity for rights and freedoms of Data Subjects posed by the Processing.

Controllers must also conduct DPIAs in respect to high-risk Processing. 

 

You should conduct a DPIA (and discuss your findings with the DPO) when implementing major system or business change programs involving the Processing of Personal Data including:

 

use of new technologies (programs, systems or processes), or changing technologies (programs, systems or processes);

large-scale, systematic monitoring of a publicly accessible area.

A DPIA must include:

 

a description of the Processing, its purposes and the Controller’s legitimate interests if appropriate; 

an assessment of the necessity and proportionality of the Processing in relation to its purpose; 

an assessment of the risk to individuals; and 

the risk mitigation measures in place and demonstration of compliance.

 

20. Direct marketing

We are subject to certain rules and privacy laws when marketing to our customers. 

 

For example, a Data Subject’s prior consent is required for electronic direct marketing (for example, by email, text or automated calls). The limited exception for existing customers known as “soft opt-in” allows organisations to send marketing texts or emails if they have obtained contact details in the course of a sale to that person, they are marketing similar products or services, and they gave the person an opportunity to opt out of marketing when first collecting the details and in every subsequent message. 

 

The right to object to direct marketing must be explicitly offered to the Data Subject in an intelligible manner so that it is clearly distinguishable from other information.

 

A Data Subject’s objection to direct marketing must be promptly honoured. If a customer opts out at any time, their details should be suppressed as soon as possible. Suppression involves retaining just enough information to ensure that marketing preferences are respected in the future.

 

21. Sharing Personal Data 

Generally we are not allowed to share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place. 

 

You may only share the Personal Data we hold with another employee, agent or representative of our group (which includes our subsidiaries and our ultimate holding company along with its subsidiaries) if the recipient has a job-related need to know the information and the transfer complies with any applicable cross-border transfer restrictions.

 

You may only share the Personal Data we hold with third parties, such as our service providers, if:

 

a) they have a need to know the information for the purposes of providing the contracted services; 

b) sharing the Personal Data complies with the Privacy Notice provided to the Data Subject and, if required, the Data Subject’s Consent has been obtained;

c) the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place;

d) the transfer complies with any applicable cross-border transfer restrictions; and 

e) a fully executed written contract that contains UK GDPR-approved third party clauses has been obtained.

 

 

22. Changes to this Data Protection Policy 

We keep this Data Protection Policy under regular review. 

 

This Data Protection Policy does not override any applicable national data privacy laws and regulations in countries where the Company operates. 

Whistleblowing

Whistleblowing Policy

1. About this policy

1.1 We are committed to conducting our business with honesty and integrity, and we expect all staff to maintain high standards. However, all organisations face the risk of things going wrong from time to time, or of unknowingly harbouring illegal or unethical conduct. A culture of openness and accountability is essential in order to prevent such situations occurring and to address them when they do occur.

 

1.2 The purpose of this policy is:

a) To encourage staff to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected.

b) To provide staff with guidance as to how to raise those concerns.

c) To reassure staff that they should be able to raise genuine concerns without fear of reprisals, even if they turn out to be mistaken.

 

1.3 This policy does not form part of any contract of employment or other contract to provide services, and we may amend it at any time.

 

2. Who does this policy apply to?

2.1 This policy applies to all employees, officers, consultants, self-employed contractors, casual workers, agency workers, volunteers and interns.

 

3. Who is responsible for this policy?

3.1 The board of directors (the Board) has overall responsibility for the effective operation of this policy, and for reviewing the effectiveness of actions taken in response to concerns raised under this policy.

 

3.2 The HR Director has day-to-day operational responsibility for this policy and you should refer any questions about this policy to them in the first instance.  HR Director must ensure that regular and appropriate training is provided to all managers and other staff who may deal with concerns or investigations under this policy.

 

3.3 This policy is reviewed at least annually by the CEO and the Board.

 

3.4 All staff are responsible for the success of this policy and should ensure that they use it to disclose any suspected danger or wrongdoing. Staff are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the HR Director where appropriate.

 

4. What is whistleblowing?

4.1 Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work. This may include:

 

a) criminal activity;

 

b) failure to comply with any legal obligation;

 

c) miscarriages of justice;

 

d) danger to health and safety;

 

e) damage to the environment; 

 

f) bribery;

 

g) facilitating tax evasion; 

 

h) breach of our internal policies and procedures;

 

i) conduct likely to damage our reputation or financial wellbeing;

 

j) unauthorised disclosure of confidential information;

 

k) negligence;

 

l) Suspicions or evidence of modern slavery or human trafficking; and

 

m) the deliberate concealment of any of the above matters.

 

4.2 A whistleblower is a person who raises a genuine concern relating to any of the above. If you have any genuine concerns related to suspected wrongdoing or danger affecting any of our activities (a whistleblowing concern) you should report it under this policy.

 

4.3 This policy should not be used for complaints relating to your own personal circumstances, such as the way you have been treated at work. In those cases you should use the Grievance Procedure. 

 

4.4 If a complaint relates to your own personal circumstances but you also have wider concerns regarding one of the areas set out at Paragraph 3.1 above (for example, a breach of our internal policies), you should discuss with the HR Director which route is the most appropriate.

 

4.5 If you are uncertain whether something is within the scope of this policy you should seek advice from the HR Director whose contact details are at the end of this policy.

 

5. Raising a whistleblowing concern

5.1 We hope that in many cases you will be able to raise any concerns with your line manager. You may tell them in person or put the matter in writing if you prefer. They may be able to agree a way of resolving your concern quickly and effectively. In some cases they may refer the matter to the HR Director

 

5.2 However, where the matter is more serious, or you feel that your line manager has not addressed your concern, or you prefer not to raise it with them for any reason, you should contact one of the following:

 

a) HR Director;

 

b) CEO.

 

Contact details are set out at the end of this policy.

 

5.3 We will arrange a meeting with you as soon as possible to discuss your concern. You may bring a colleague or union representative to any meetings under this policy. Your companion must respect the confidentiality of your disclosure and any subsequent investigation. 

 

5.4 We will take down a written summary of your concern and provide you with a copy after the meeting. We will also aim to give you an indication of how we propose to deal with the matter.

 

6. Confidentiality

6.1 We hope that staff will feel able to voice whistleblowing concerns openly under this policy. However, if you want to raise your concern confidentially, we will make every effort to keep your identity secret. If it is necessary for anyone investigating your concern to know your identity, we will discuss this with you.

 

6.2 We do not encourage staff to make disclosures anonymously. Proper investigation may be more difficult or impossible if we cannot obtain further information from you. It is also more difficult to establish whether any allegations are credible. Whistleblowers who are concerned about possible reprisals if their identity is revealed should come forward to the HR Director and appropriate measures can then be taken to preserve confidentiality. If you are in any doubt you can seek advice from Protect, the independent whistleblowing charity, who offer a confidential helpline. Their contact details are at the end of this policy.

 

7. Investigation and outcome

7.1 Once you have raised a concern, we will carry out an initial assessment to determine the scope of any investigation. We will inform you of the outcome of our assessment. You may be required to attend additional meetings in order to provide further information.

 

7.2 In some cases we may appoint an investigator or team of investigators including staff with relevant experience of investigations or specialist knowledge of the subject matter. The investigator(s) may make recommendations for change to enable us to minimise the risk of future wrongdoing.

 

7.3 We will aim to keep you informed of the progress of the investigation and its likely timescale. However, sometimes the need for confidentiality may prevent us giving you specific details of the investigation or any disciplinary action taken as a result. You should treat any information about the investigation as confidential.

 

7.4 If we conclude that a whistleblower has made false allegations maliciously, the whistleblower will be subject to disciplinary action. 

 

8. If you are not satisfied

8.1 While we cannot always guarantee the outcome you are seeking, we will try to deal with your concern fairly and in an appropriate way. By using this policy you can help us to achieve this.

 

8.2 If you are not happy with the way in which your concern has been handled, you can raise it with the Chairman. Contact details are set out at the end of this policy.

 

9. External disclosures

9.1 The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases you should not find it necessary to alert anyone externally. 

 

9.2 The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. It will very rarely if ever be appropriate to alert the media. We strongly encourage you to seek advice before reporting a concern to anyone external. The independent whistleblowing charity, Protect, operates a confidential helpline. They also have a list of prescribed regulators for reporting certain types of concern. Their contact details are at the end of this policy.

 

9.3 Whistleblowing concerns usually relate to the conduct of our staff, but they may sometimes relate to the actions of a third party, such as a customer, supplier or service provider. In some circumstances the law will protect you if you raise the matter with the third party directly. However, we encourage you to report such concerns internally first. You should contact your line manager for guidance. 

 

10. Protection and support for whistleblowers

10.1 It is understandable that whistleblowers are sometimes worried about possible repercussions. We aim to encourage openness and will support staff who raise genuine concerns under this policy, even if they turn out to be mistaken.

 

10.2 Whistleblowers must not suffer any detrimental treatment as a result of raising a concern. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the HR Director immediately. If the matter is not remedied you should raise it formally using our Grievance Procedure. 

 

10.3 You must not threaten or retaliate against whistleblowers in any way. If you are involved in such conduct you may be subject to disciplinary action. In some cases the whistleblower could have a right to sue you personally for compensation in an employment tribunal.

 

11. Contacts

CEO and Chairman

Karl Hick

Telephone: 01778 391573

Email: Karl.hick@phoenix-sustainable.co.uk

 

Protect (Independent whistleblowing charity)

Helpline: 0203 1172520

Email: infor@protect-advice.org.uk

Website: https://protect-advice.org.uk/contact-protect-advice-line/ 

 

 

The Phoenix Sustainable Investments Modern Slavery and Human Trafficking Statement

Introduction from the CEO and Chairman – Karl Hick

 

This statement is made in accordance with the Modern Slavery Act 2015 (the Act). It explains our approach to prevent modern slavery and human trafficking from occurring in our business and our supply chains.

 

Slavery and human trafficking are unacceptable. Slavery and human trafficking cause horrendous harm to the individuals that are subject to it, destroying peoples’ lives and fuelling further criminal activity. The board of directors (Board) and I take our responsibility to preventing modern slavery and human trafficking within our business and within our supply chains, extremely seriously. 

 

The Board continue to look closely at our activity, our business, our supply chain partners and our staff and employees to ensure that not only to make sure that we conduct our business in way that is respectful to others but also that any signs are such activity are spotted early or prevented in the first place. 

 

We want to ensure that all of our employees understand that if they spot any signs of such activity, we, as their employer, have informed them of the actions to take and that it is brought to the attention of the Board immediately and without delay. 

 

Below we have set out in more detail our approach, our expectation and requirements of our supply chain and what we are doing to fulfil this fundamental responsibility. 

 

Organisation’s structure

The Phoenix Sustainable Investments is an award-winning Construction, Research & Development and Sustainable Technology business based in Bourne, Lincolnshire. 

 

Our supply chains

Our supply chains include construction materials suppliers, labour sub-contractors, service providers and professional consultants and advisors.  

 

Our policies on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. 

 

Internal and external processes for slavery and human trafficking identification

As part of our initiative to identify and mitigate risk we undertake due diligence of our suppliers to ensure that they are not subject to significant risk of slavery and that they have published or evidence of policies and procedures in place to prevent modern slavery. We also consider their geographical location, the type of supplier, financial risk and any specific modern slavery or human rights issues/concerns. 

 

As part of our due diligence, we assess each supplier to:

 

Identify and assess potential risk areas in our supply chains.

Mitigate the risk of slavery and human trafficking occurring in our supply chains.

Monitor potential risk areas in our supply chains.

Protect whistle blowers.

 

Expectations of our suppliers

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values, we expect all suppliers to have robust systems and procedures in place to identify and prevent modern slavery and human trafficking. Whilst we undertake due diligence on suppliers, it should go without saying that we expect each and every supplier to the Phoenix Sustainable Investments to also have a zero-tolerance approach to slavery and human trafficking. It is only if everyone works together throughout the supply chain to identify and prevent it that we will all succeed in tackling slavery and human trafficking.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff. We also require our business partners to provide training to their staff and suppliers and providers.

Our effectiveness in combating slavery and human trafficking

In 2018 we continued to assess our operations and supply chain. We informed our suppliers of their need to report any instances of modern slavery and human trafficking and informed them of the law, our position and actions they must take. We have identified that the highest risk to our business and supply chain were where there were migrant and low-skilled labour. Working with primarily subcontractors it was of importance that we also educated our supply chain. 

 

Over the past 12 months, we have:

 

Updated our company polices, including modern slavery.

Updated our Whistleblowing Policy is up to date and adequately covers instances of modern slavery and human trafficking and how we will protect any individual (supplier or employee) coming forward to us; and

Encouraged all of our supply chain to confirm that they are taking positive steps to eliminate human trafficking and modern slavery.

Following a review of the effectiveness of the steps we have taken this year to ensure that there is no slavery or human trafficking in our supply chains we intend to take the following further steps to combat slavery and human trafficking: 

 

To train any new staff in order to provide staff awareness of the Modern Slavery Act 2015 and reporting mechanisms if a case of slavery or human trafficking is suspected.

Continue to monitor our supply chain and ensure that any new suppliers are aware of their obligations.

Undertake due diligence to ensure continued compliance with the Act;

Keep under review, this Policy and our approach to tackling the issue of Modern Slavery.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year ending 30 June 2022. It was approved by the board and Karl Hick (CEO) on 5th January 2022. 

Equal opportunities

Equal Opportunities Statement

1. Equal Opportunities Statement

Phoenix Sustainable Investments (and its associated group of companies) prides itself on being an equal opportunities employer and is committed to promoting equal opportunities in employment. You and any job applicants will receive equal treatment regardless of age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation (Protected Characteristics).

 

2. About this policy

2.1 This policy sets out our approach to equal opportunities and the avoidance of discrimination at work. It applies to all aspects of employment or working with us, including recruitment, pay and conditions, training, appraisals, promotion, conduct at work, disciplinary and grievance procedures, and termination of employment.

 

2.2 This policy covers all employees, officers, consultants, contractors, casual workers and agency workers and all companies within the Phoenix.

 

2.3 This policy does not form part of any employee’s contract of employment and we may amend it at any time.

 

3. Who is responsible for this policy?

3.1 Our board of directors (the board) has overall responsibility for the effective operation of this policy and for ensuring compliance with discrimination law. Day-to-day operational responsibility for this policy, including regular review of this policy, has been delegated to Helen Hick, the HR Director.

 

3.2 All managers must set an appropriate standard of behaviour, lead by example and ensure that those they manage adhere to the policy and promote our aims and objectives regarding equal opportunities. Managers will be given appropriate training on equal opportunities awareness and equal opportunities recruitment and selection best practice. Helen Hick has overall responsibility for equal opportunities training.

 

3.3 If you are involved in management or recruitment, or if you have any questions about the content or application of this policy, you should contact the HR department to request training or further information.

 

3.4 This policy is reviewed annually by the Board and the CEO.

 

3.5 Staff are invited to comment on this policy and suggest ways in which it might be improved by contacting Helen Hick, the HR Director.

 

4. Discrimination

4.1 You must not unlawfully discriminate against or harass other people including current and former employees, job applicants, clients, customers, suppliers and visitors. This applies in the workplace, outside the workplace (when dealing with customers, suppliers or other work-related contacts or when wearing a work uniform), and on work-related trips or events including social events.

 

4.2 The following forms of discrimination are prohibited under this policy and are unlawful:

 

a) Direct discrimination: treating someone less favourably because of a Protected Characteristic. For example, rejecting a job applicant because of their religious views or because they might be gay.

 

b) Indirect discrimination: a provision, criterion or practice that applies to everyone but adversely affects people with a particular Protected Characteristic more than others and is not justified. For example, requiring a job to be done full-time rather than part-time would adversely affect women because they generally have greater childcare commitments than men. Such a requirement would be discriminatory unless it can be justified.

 

c) Harassment: this includes sexual harassment and other unwanted conduct related to a Protected Characteristic, which has the purpose or effect of violating someone’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. Harassment is dealt with further in our Anti-harassment and Bullying Policy.

 

d) Victimisation: retaliation against someone who has complained or has supported someone else’s complaint about discrimination or harassment. 

 

e) Disability discrimination: this includes direct and indirect discrimination, any unjustified less favourable treatment because of the effects of a disability, and failure to make reasonable adjustments to alleviate disadvantages caused by a disability.

 

5. Recruitment and selection

5.1 Recruitment, promotion, and other selection exercises such as redundancy selection will be conducted on the basis of merit, against objective criteria that avoid discrimination. Shortlisting should be done by more than one person and with the involvement of the Human Resources Department, where possible. Our recruitment procedures should be reviewed regularly to ensure that individuals are treated on the basis of their relevant merits and abilities.

 

5.2 Vacancies should generally be advertised to a diverse section of the labour market. Advertisements should avoid stereotyping or using wording that may discourage particular groups from applying.

 

5.3 We take steps to ensure that our vacancies are advertised to a diverse labour market. Where appropriate, the Human Resources Department may approve the use of lawful exemptions to recruit someone with a particular Protected Characteristic, for example, where the job can only be done by a woman. The advertisement should specify the exemption that applies.

 

5.4 Job applicants should not be asked questions which might suggest an intention to discriminate on grounds of a Protected Characteristic. For example, applicants should not be asked whether they are pregnant or planning to have children.

 

5.5 Job applicants should not be asked about health or disability before a job offer is made. There are limited exceptions which should only be used with the approval of the Human Resources Department. For example:

 

a) Questions necessary to establish if an applicant can perform an intrinsic part of the job (subject to any reasonable adjustments).

 

b) Questions to establish if an applicant is fit to attend an assessment or any reasonable adjustments that may be needed at interview or assessment. 

 

c) Positive action to recruit disabled persons.

 

d) Equal opportunities monitoring (which will not form part of the selection or decision-making process).

 

Where necessary, job offers can be made conditional on a satisfactory medical check.

 

5.6 We are required by law to ensure that all employees are entitled to work in the UK. Assumptions about immigration status should not be made based on appearance or apparent nationality. All prospective employees, regardless of nationality, must be able to produce original documents (such as a passport) before employment starts, to satisfy current immigration legislation. The list of acceptable documents is available from UK Visas and Immigration.

 

5.7 To ensure that this policy is operating effectively, and to identify groups that may be underrepresented or disadvantaged in our organisation, we monitor applicants’ ethnic group, gender, disability, sexual orientation, religion and age as part of the recruitment procedure. Provision of this information is voluntary and it will not adversely affect an individual’s chances of recruitment or any other decision related to their employment. The information is removed from applications before shortlisting and kept in an anonymised format solely for the purposes stated in this policy. Analysing this data helps us take appropriate steps to avoid discrimination and improve equality and diversity.

 

6. Training and promotion and conditions of service

6.1 Training needs will be identified through regular appraisals. You will be given appropriate access to training to enable you to progress within the organisation and all promotion decisions will be made on the basis of merit. 

 

6.2 Our conditions of service, benefits and facilities are reviewed regularly to ensure that they are available to all of you who should have access to them and that there are no unlawful obstacles to accessing them. 

 

7. Termination of employment

7.1 We will ensure that redundancy criteria and procedures are fair and objective and are not directly or indirectly discriminatory.

 

7.2 We will also ensure that disciplinary procedures and penalties are applied without discrimination, whether they result in disciplinary warnings, dismissal or other disciplinary action. 

 

8. Disabilities

8.1 If you are disabled or become disabled, we encourage you to tell us about your condition so that we can support you as appropriate. 

 

8.2 If you experience difficulties at work because of your disability, you may wish to contact the Human Resources department to discuss any reasonable adjustments that would help overcome or minimise the difficulty. The Human Resources Department may wish to consult with you and your medical adviser about possible adjustments. We will consider the matter carefully and try to accommodate your needs within reason. If we consider a particular adjustment would not be reasonable, we will explain our reasons and try to find an alternative solution where possible. 

 

8.3 We will monitor the physical features of our premises to consider whether they might place anyone with a disability at a substantial disadvantage. Where necessary, we will take reasonable steps to improve access.

 

9. Part-time and fixed-term work

Part-time and fixed-term staff should be treated the same as comparable full-time or permanent staff and enjoy no less favourable terms and conditions (on a pro-rata basis where appropriate), unless different treatment is justified. 

 

10. Breaches of this policy

10.1 We take a strict approach to breaches of this policy, which will be dealt with in accordance with our Disciplinary Procedure. Serious cases of deliberate discrimination may amount to gross misconduct resulting in dismissal.

 

10.2 If you believe that you have suffered discrimination you can raise the matter through our Grievance Procedure or through our Anti-harassment and Bullying Policy as appropriate. Complaints will be treated in confidence and investigated as appropriate.

 

10.3 There must be no victimisation or retaliation against staff who complain about discrimination. However, making a false allegation deliberately and in bad faith will be treated as misconduct and dealt with under our Disciplinary Procedure.

 

11. Related policies

This policy is supported by the following other policies and procedures:

 

a) Anti-Harassment and Bullying Policy.

 

b) Grievance Procedure.

 

c) Disciplinary Procedure.

 

d) Flexible Working Procedure

 

e) Maternity, Paternity, Adoption and Shared Parental Leave Policies.

 

f) Parental Leave Policy.

 

g) Time Off for Dependants Policy.

 

h) Dress Code.

 

i) Homeworking Policy.

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