Compliance & Governance

Policies & Statements

All PLUMS Limited policies are reviewed annually or following any significant regulatory or legislative change. These documents are effective as of the review dates shown.

Jump to a policy
Safeguarding
Safeguarding & Child Protection Policy
Reviewed: September 2024 Next review: September 2025 Owner: Designated Safeguarding Lead

1. Purpose and Scope

PLUMS Limited is committed to safeguarding and promoting the welfare of all learners, including children and adults at risk. This policy applies to all staff, contractors, Skills Coaches, volunteers and subcontractors working on behalf of PLUMS Limited.

2. Designated Safeguarding Lead

PLUMS Limited has a designated Safeguarding Lead (DSL) who holds a minimum of Level 3 safeguarding training. The DSL is responsible for managing all safeguarding referrals, maintaining records, liaising with statutory agencies and ensuring the organisation meets its legal duties. All staff are aware of the DSL's contact details.

3. Safer Recruitment

All PLUMS Limited staff undergo enhanced DBS (Disclosure and Barring Service) checks before commencing employment. References are obtained and verified. Staff are not permitted to commence working with learners before clearance is confirmed. DBS checks are renewed every three years or sooner if required.

4. Recognising and Reporting Concerns

All staff have a duty to report safeguarding concerns. Concerns must be raised immediately with the DSL. Where a child or adult is believed to be at immediate risk, the DSL will notify the relevant statutory agency without delay. Concerns are recorded using our secure safeguarding log. Confidentiality is maintained except where disclosure is required for the protection of the individual.

5. Training and Awareness

All staff receive safeguarding training at induction and at intervals no greater than two years. Skills Coaches receive additional training relevant to their work with learners in employer premises. Safeguarding is included in all learner inductions.

6. British Values and Prevent

PLUMS Limited promotes British values — democracy, the rule of law, individual liberty, and mutual respect and tolerance — throughout all programmes. Staff are trained in the Prevent duty and are alert to signs of radicalisation or extremist influence. Concerns are reported to the DSL who will make referrals through the Channel process where appropriate.

7. Policy Review

This policy is reviewed annually by the DSL and senior leadership, and updated following any change in statutory guidance. The policy is available to all learners, employers and staff on request.

Counter-Extremism
Prevent Duty Statement
Reviewed: September 2024 Next review: September 2025 Owner: Designated Safeguarding Lead

1. Our Commitment

PLUMS Limited fully supports the government's Prevent strategy and our duties under the Counter-Terrorism and Security Act 2015. We are committed to protecting learners, staff and employers from the threat of terrorism and radicalisation.

2. Risk Assessment

PLUMS Limited carries out an annual Prevent risk assessment to identify vulnerabilities and put in place appropriate measures. This assessment considers the nature of our learner cohort, delivery environments, and any local or national threats identified by Prevent co-ordinators.

3. Staff Training

All staff complete WRAP (Workshop to Raise Awareness of Prevent) training or an equivalent approved programme at induction and at intervals no greater than three years. New staff complete training before working with learners unsupervised.

4. Raising Concerns

Any member of staff who believes a learner may be at risk of radicalisation or involvement in extremism must raise the concern with the Designated Safeguarding Lead immediately. The DSL will review the concern and, where appropriate, make a referral through the Channel voluntary programme. Records of concerns and referrals are maintained securely.

5. Curriculum and British Values

PLUMS Limited embeds British values across all programmes. Learners are encouraged to develop respect for the rule of law, individual liberty and mutual tolerance. Discussion of extremist views in any form is not permitted on PLUMS Limited programmes.

6. Online Safety

Where online learning platforms are used, PLUMS Limited monitors usage and takes steps to prevent access to extremist or harmful content. Learners are educated on safe and responsible online behaviour at induction.

Data & Privacy
GDPR & Data Protection Policy
Reviewed: January 2025 Next review: January 2026 Owner: Data Protection Officer

1. Policy Statement

PLUMS Limited processes personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. This policy sets out how we collect, use, store and protect personal data relating to learners, staff, employers and other individuals.

2. Lawful Basis for Processing

PLUMS Limited processes personal data on the following lawful bases: performance of a contract (apprenticeship agreements); compliance with a legal obligation (ESFA ILR reporting); legitimate interests (managing our training provision); and consent (marketing communications, where sought).

3. Data We Collect

  • Learner personal and contact information, prior qualifications and employment details
  • Employer contact details and payroll information relevant to apprenticeship funding
  • Assessment records, portfolio evidence and progress data
  • Sensitive personal data including ethnicity, disability status and health information where relevant to learning support
  • ESFA Individual Learner Record (ILR) data required under our funding contract

4. Data Retention

Learner records are retained for seven years following completion or withdrawal, in line with ESFA contract requirements. Staff records are retained for six years following the end of employment. Marketing consent records are retained for three years from the date consent was given or last confirmed.

5. Your Rights

Data subjects have the right to access, rectify, erase, restrict processing of, and port their personal data. To exercise any of these rights, contact our Data Protection Officer at [email protected]. We will respond within 30 days.

6. Data Security

Personal data is held on secure, access-controlled systems. Staff are trained on data handling at induction. Data breaches are reported to the Information Commissioner's Office within 72 hours if they are likely to result in a risk to individuals.

Health & Safety
Health & Safety Policy Statement
Reviewed: March 2025 Next review: March 2026 Owner: Operations Director

1. Statement of Intent

PLUMS Limited is committed to providing and maintaining safe and healthy working conditions, equipment and systems of work for all employees, contractors and learners. We comply with the Health and Safety at Work etc. Act 1974 and all associated regulations.

2. Responsibilities

Senior leadership is responsible for ensuring this policy is implemented and resourced. Each Skills Coach is responsible for conducting and recording risk assessments for each employer delivery site before commencing visits. Employers are responsible for the day-to-day health and safety of apprentices in their premises under their own health and safety obligations.

3. Employer Site Assessments

PLUMS Limited conducts a health and safety site review of all employer premises before placing a learner and at intervals no greater than 12 months. The review covers fire safety, COSHH (chemical hazards common in salon environments), manual handling, electrical safety and first aid provision. Where risks are identified, the employer is required to take corrective action before training commences.

4. COSHH in the Salon

Hair and beauty environments involve regular use of chemical products. PLUMS Limited ensures all learners receive training in safe handling of chemicals including relaxers, bleach, colourants and adhesives as part of their programme. Learners are instructed to use appropriate PPE at all times and to report any adverse reactions immediately.

5. Accidents and Incidents

All accidents, near misses and incidents involving PLUMS Limited learners or staff must be reported to the Operations team within 24 hours. RIDDOR-reportable incidents are reported to the Health and Safety Executive. All incidents are recorded and reviewed to identify preventative action.

6. Mental Health and Wellbeing

PLUMS Limited recognises the importance of mental health and wellbeing. All learners have access to wellbeing support through their Skills Coach and via our confidential learner helpline. Staff have access to an Employee Assistance Programme.

Equality
Equality, Diversity & Inclusion Policy
Reviewed: September 2024 Next review: September 2025 Owner: Senior Leadership Team

1. Commitment

PLUMS Limited is committed to promoting equality of opportunity and celebrating diversity across all aspects of our work. We comply with the Equality Act 2010 and ensure that no learner, employee or employer is treated less favourably because of a protected characteristic.

2. Protected Characteristics

This policy covers all nine protected characteristics defined under the Equality Act 2010: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.

3. Learner Admissions

PLUMS Limited assesses all applicants against published eligibility criteria only. No applicant is refused a place on grounds related to a protected characteristic. Reasonable adjustments are made for learners with disabilities or learning difficulties throughout recruitment, delivery and assessment.

4. EDI in Curriculum Delivery

Our curriculum content reflects the diversity of the communities we serve and the clients that our learners will work with. Skills Coaches receive training in inclusive delivery and are expected to challenge discriminatory language or behaviour where observed in delivery settings.

5. Monitoring and Reporting

PLUMS Limited monitors learner enrolment, achievement and withdrawal data by protected characteristic. Where disparities are identified, these are investigated and addressed through the Quality Improvement Plan. Equality data is included in the annual Self-Assessment Report.

6. Reporting Discrimination

Any learner, member of staff or employer who believes they have been subject to discrimination, harassment or victimisation should report this using our Complaints procedure. All reports are investigated impartially and confidentially.

Quality
Complaints & Appeals Procedure
Reviewed: September 2024 Next review: September 2025 Owner: Quality Assurance Manager

1. Purpose

PLUMS Limited is committed to delivering high-quality training and to resolving any concerns promptly and fairly. This procedure applies to complaints from learners, employers and any other stakeholder, and to appeals against assessment decisions.

2. Informal Resolution (Stage 1)

In the first instance, complainants are encouraged to raise the matter informally with their Skills Coach or with the member of staff concerned. The majority of concerns can be resolved at this stage within five working days.

3. Formal Complaint (Stage 2)

If the matter is not resolved informally, a formal complaint may be submitted in writing to the Quality Assurance Manager at [email protected]. We will acknowledge receipt within two working days and provide a full written response within 15 working days.

4. Review (Stage 3)

If the complainant remains dissatisfied following the formal response, they may request a review by the Managing Director within ten working days of receiving the Stage 2 response. The review decision is final as far as PLUMS Limited's internal procedure is concerned.

5. External Escalation

If a complainant is not satisfied with the outcome of the internal procedure, they may refer the matter to the ESFA, Ofsted or the relevant awarding organisation. Details of external bodies and how to contact them are provided in the Stage 3 response letter.

6. Assessment Appeals

Learners who wish to appeal against an internal assessment decision must do so in writing within ten working days of receiving their result. Appeals against EPA decisions are handled by the relevant EPA organisation (VTCT / NCFE or City & Guilds) in accordance with their own appeals procedure.

Funding
Subcontracting Policy & Register
Reviewed: August 2024 Next review: August 2025 Owner: Finance & Contracts Director

1. Policy Statement

PLUMS Limited is a Main Provider on the ESFA Register of Apprenticeship Training Providers. Where PLUMS Limited enters into subcontracting arrangements for the delivery of apprenticeship training, it does so in accordance with ESFA funding rules and the requirements of its ESFA contract.

2. Approval of Subcontractors

No subcontracting arrangement may commence without the prior written approval of the Finance & Contracts Director. Due diligence is carried out on all proposed subcontractors including financial health checks, quality assurance capacity assessments and confirmation of any required registrations or approvals.

3. Subcontractor Register

PLUMS Limited maintains a public register of all subcontractors. For the current academic year (2024–25), PLUMS Limited delivers all funded provision directly and does not currently engage subcontractors for apprenticeship delivery. This register will be updated if any subcontracting arrangements are entered into.

4. Quality Assurance of Subcontracted Provision

Where subcontractors are engaged, PLUMS Limited retains responsibility for the quality of all provision funded through its ESFA contract. Subcontractors are subject to monitoring visits, learner outcome reviews and compliance audits at intervals defined in the subcontract agreement.

5. Fee Transparency

In accordance with ESFA requirements, PLUMS Limited publishes the fees retained and paid to subcontractors. This information is included in the annual subcontracting register published on this page.

Ethics
Modern Slavery Act Statement
Reviewed: April 2025 Next review: April 2026 Owner: Managing Director

1. Our Commitment

PLUMS Limited has zero tolerance for modern slavery in any form, including forced labour, human trafficking, child labour and debt bondage. We are committed to acting ethically and with integrity in all our business relationships.

2. Our Business

PLUMS Limited operates as an apprenticeship training provider in the hair and beauty sector. Our workforce consists of employed staff and self-employed Skills Coaches. We work with employer partners across Bedfordshire and the East of England.

3. Supply Chains

Our principal supply chains include learning management system providers, awarding organisations, assessment resources and office supplies. We carry out due diligence on key suppliers, including reviewing their own modern slavery statements where published.

4. Due Diligence and Risk Assessment

PLUMS Limited assesses the risk of modern slavery in our operations and supply chains. The hair and beauty sector carries specific risks given the prevalence of informal employment. Our employer onboarding process includes verification of employment contracts and appropriate pay for all apprentices.

5. Training and Awareness

All staff receive awareness training on identifying potential indicators of modern slavery. Skills Coaches are trained to recognise signs of exploitation in salon and barbershop environments and know how to report concerns.

6. Reporting

Any person who suspects modern slavery in connection with PLUMS Limited's operations or supply chains should report this to the Managing Director or, anonymously, via the Modern Slavery Helpline on 0800 0121 700.

Ethics
Anti-Bribery & Corruption Policy
Reviewed: September 2024 Next review: September 2025 Owner: Managing Director

1. Policy Statement

PLUMS Limited has a zero-tolerance approach to bribery and corruption. We comply with the Bribery Act 2010 and are committed to carrying out all business honestly and with integrity.

2. What Counts as Bribery

Bribery includes offering, giving, requesting or receiving any financial or other advantage intended to induce or reward improper conduct. This applies to dealings with public bodies, private organisations, employers, awarding organisations and any other third party.

3. Gifts and Hospitality

Staff may accept minor, unsolicited gifts of a token value (not exceeding £25) where refusal would cause offence. All gifts must be declared to line management and recorded in the gifts register. No gift may be accepted or given where it could be perceived as influencing a business decision.

4. Responsibilities

All PLUMS Limited employees and contractors are required to read, understand and comply with this policy. The Managing Director has overall responsibility for ensuring compliance. Any person who becomes aware of potential bribery or corruption must report this through the Whistleblowing procedure.

5. Consequences

Breach of this policy by an employee will result in disciplinary action up to and including dismissal. Where criminal offences are suspected, the matter will be reported to the relevant authorities.

Governance
Whistleblowing Policy
Reviewed: September 2024 Next review: September 2025 Owner: Managing Director

1. Purpose

This policy enables staff, learners, employers and contractors to raise concerns about illegal activity, financial irregularity, safeguarding failures, serious health and safety risks, or other malpractice — without fear of detriment or victimisation.

2. Protected Disclosures

PLUMS Limited operates within the framework of the Public Interest Disclosure Act 1998. Workers who make a qualifying disclosure in good faith are protected from detriment. Disclosures must relate to one of the categories defined in the Act: criminal offences, legal obligations, miscarriages of justice, health and safety dangers, environmental damage, or cover-ups.

3. How to Raise a Concern

Concerns may be raised with the Managing Director verbally or in writing at [email protected]. Where the concern relates to the Managing Director, it should be raised with the Chair of the Board. Anonymous disclosures may also be made via our confidential helpline.

4. Investigation

All disclosures are acknowledged within five working days. The matter will be investigated promptly and impartially by a person with no direct involvement in the concern raised. The outcome will be communicated to the discloser unless doing so would identify other individuals or compromise a formal investigation.

5. External Disclosure

If internal routes are unavailable or if the discloser reasonably believes the concern will be suppressed, disclosure may be made to a prescribed body such as the ESFA, Ofsted, HMRC or the Police. PLUMS Limited will not penalise any person for making a disclosure to a prescribed body in good faith.

Staff Safety
Lone Working Policy
Reviewed: March 2025 Next review: March 2026 Owner: Operations Director

1. Scope

This policy applies to all PLUMS Limited staff and Skills Coaches who work alone, including when conducting employer visits, home visits or working from locations other than the main office.

2. Risk Assessment

A lone working risk assessment is completed for all regular lone working activities. Risk factors include travel, the nature of the visit location, time of day, and any known risks associated with the employer site or individual being visited.

3. Check-In Procedures

All staff lone working must complete a check-in and check-out procedure. Before a visit, the staff member informs a designated colleague of their location, expected duration and contact number. If the check-out call is not received within the agreed timeframe, the designated colleague follows the escalation procedure.

4. Personal Safety

Staff are advised to trust their instincts. If a situation feels unsafe, staff have the right to leave immediately without obligation to complete the visit. Any safety incident involving a lone worker must be reported to the Operations Director and recorded within 24 hours.

5. Communication Devices

All lone workers are provided with a charged mobile phone and are expected to keep it accessible throughout visits. Emergency contact numbers are pre-stored on all devices. In areas with poor signal, alternative arrangements are agreed in advance.

Delivery
Remote Learning & Online Delivery Policy
Reviewed: January 2025 Next review: January 2026 Owner: Quality Assurance Manager

1. Policy Statement

PLUMS Limited uses a blended delivery model that includes remote and online elements. This policy sets out the standards and expectations for online and remote delivery to ensure that quality is maintained and that all learners receive an equivalent experience regardless of delivery mode.

2. Eligible Activities

Remote delivery may be used for off-the-job theory sessions, portfolio reviews, progress reviews, 1:1 coaching sessions and structured online learning modules. Practical skills assessments and EPA activities must be conducted in person.

3. Platform and Technology Standards

All remote sessions are conducted via approved, secure video conferencing platforms. Sessions must not be recorded without the explicit consent of all participants. Learners without adequate home internet access are supported to identify alternatives.

4. Safeguarding in Remote Settings

Safeguarding procedures apply fully to remote delivery. Remote sessions involving learners under 18 must not be conducted on a 1:1 basis without a parent, carer or second adult present unless explicit parental consent has been obtained. Safeguarding concerns arising in remote settings are reported through the standard procedure.

5. Recording Off-the-Job Training

Remote learning activities that qualify as off-the-job training are recorded in the learner's digital portfolio in the same way as in-person activities. The nature of the activity, duration and learning outcomes are documented for each session.

Learner Management
Learner Withdrawal & Transfer Policy
Reviewed: September 2024 Next review: September 2025 Owner: Learner Services Manager

1. Purpose

PLUMS Limited recognises that, in some circumstances, learners may need to withdraw from or transfer their apprenticeship. This policy ensures that withdrawals and transfers are handled sensitively, in compliance with ESFA funding rules, and with the learner's best interests in mind.

2. Break in Learning

Where a learner's circumstances change temporarily (illness, family circumstances, employer change), a break in learning may be agreed. Breaks may not exceed four weeks without formal ESFA notification. The planned end date is extended by the duration of the break.

3. Transfer to Another Provider

Where a learner wishes to transfer to a different training provider, PLUMS Limited will support the transfer process in a timely manner. All evidence, portfolios and prior learning records will be shared with the receiving provider within ten working days of a written transfer request, subject to data protection requirements.

4. Employer Change

Where an apprentice changes employer during the programme, PLUMS Limited will support the learner in identifying a suitable new employer placement. The apprenticeship may continue provided a new employer can be confirmed within a reasonable timeframe and the new employer meets the required criteria.

5. Withdrawal

Where withdrawal cannot be avoided, the learner will receive an exit interview to document the reasons, identify any outstanding support needs and discuss future options. ESFA ILR data is updated within the required timeframe following withdrawal. Learners are provided with information on alternative education and training routes.

Recognition
Recognition of Prior Learning (RPL) Policy
Reviewed: September 2024 Next review: September 2025 Owner: Quality Assurance Manager

1. Definition

Recognition of Prior Learning (RPL) is the process by which PLUMS Limited formally recognises and credits a learner's existing knowledge, skills and behaviours against the requirements of an apprenticeship standard, potentially reducing the minimum duration of the programme.

2. Eligibility for RPL

RPL is available to learners who hold relevant qualifications or who can demonstrate occupational competency through documented work experience. RPL cannot reduce a programme below 12 months in total, in accordance with ESFA funding rules.

3. RPL Assessment Process

  1. The learner submits evidence of prior learning (certificates, employment records, employer testimony)
  2. The Skills Coach and Internal Quality Assurer review the evidence against the occupational standard
  3. A formal RPL assessment is conducted and documented
  4. The agreed credit and revised programme plan are recorded in the learner's Individual Learning Plan

4. EPA and RPL

RPL does not exempt a learner from end-point assessment. All learners must complete the EPA in full regardless of any prior learning credit awarded during the programme.

5. Appeals

Where a learner disagrees with an RPL decision, they may appeal in writing within ten working days using the Complaints & Appeals procedure.

Guidance
Information, Advice & Guidance (IAG) Policy
Reviewed: September 2024 Next review: September 2025 Owner: Learner Services Manager

1. Commitment

PLUMS Limited is committed to providing high-quality, impartial information, advice and guidance to all prospective and current learners, enabling them to make well-informed decisions about their education, training and career.

2. Pre-Entry IAG

All prospective learners receive a pre-enrolment IAG session before signing any apprenticeship agreement. This covers programme content, duration, expectations, funding arrangements, EPA requirements, progression routes and alternatives. Learners are never pressured into a programme that is not appropriate for their needs.

3. Initial Assessment

All learners complete an initial skills assessment prior to enrolment covering English, maths and vocational knowledge. The results inform the Individual Learning Plan and identify any additional support requirements including Functional Skills.

4. Ongoing Guidance

Learners have access to IAG support throughout their programme via their Skills Coach, who conducts a formal progress review at a minimum of every four weeks. Careers guidance is provided at least once during the programme, including information on progression routes into employment, further study or self-employment within the sector.

5. Impartiality

All IAG provided by PLUMS Limited is impartial. Learners are informed about a full range of learning options — not only those offered by PLUMS Limited — and are not advised to enrol on a programme that does not meet their needs.

Quality
Quality Improvement Plan (QIP) 2024–25
Current cycle: September 2024 – August 2025 Owner: Quality Assurance Manager

Context

The Quality Improvement Plan is produced annually following completion of the Self-Assessment Report (SAR). It sets out the key areas for development identified through self-assessment, learner and employer feedback, and performance data analysis.

Priority 1 — Increase Timely Achievement Rates

Target: Increase the proportion of learners completing within the planned end date from 81% to 88% by August 2025.
Actions: Implement early-alert tracking for learners at risk of delay; introduce monthly gateway readiness checks from month 12; strengthen employer briefings on off-the-job recording requirements.

Priority 2 — Strengthen Employer Engagement

Target: Achieve an employer satisfaction score of 96% or above in the 2024–25 annual survey.
Actions: Introduce a mid-programme employer check-in call at month nine; develop an employer portal for real-time progress visibility; provide a refreshed employer guide to apprenticeship obligations.

Priority 3 — Improve Functional Skills Achievement

Target: Increase Functional Skills English and maths achievement rates to 90%.
Actions: Introduce an additional Functional Skills support session for learners at risk; implement a structured revision programme in the three months preceding assessment; review assessment booking lead times.

Review Schedule

Progress against QIP actions is reviewed monthly by the Quality Assurance Manager and reported to the Senior Leadership Team quarterly. The QIP is updated to reflect progress and any new priorities identified during the year.

Self-Assessment
Self-Assessment Report (SAR) 2023–24
Published: November 2024 Academic year: August 2023 – July 2024 Owner: Quality Assurance Manager

Overall Grade: Good

PLUMS Limited judges its overall effectiveness as Good for the academic year 2023–24. This judgement is based on evaluation against the Ofsted Education Inspection Framework and the ESFA apprenticeship quality framework.

Quality of Education: Good

The curriculum is well-planned and sequenced. Skills Coaches have strong vocational expertise and are effective in linking theoretical knowledge to practical application in the salon. Learner feedback is consistently positive regarding the quality and relevance of coaching. Assessment practice is fair and standardised. The proportion of learners achieving at Merit or Distinction at EPA increased from 82% to 89% compared to the prior year.

Behaviour and Attitudes: Good

Learner attendance at off-the-job activities improved to 93%. Employer reports indicate that apprentices demonstrate professional conduct and positive attitudes in the workplace. Learner surveys report high levels of confidence in their vocational skills.

Personal Development: Good

Learners receive effective careers guidance and understand their progression options. British values and PREVENT are embedded throughout delivery. Wellbeing support is accessible and learners are aware of how to seek help.

Leadership and Management: Good

Governance arrangements are effective. Self-assessment is rigorous and supported by robust data. The Quality Improvement Plan is implemented and monitored. Staff receive appropriate continuing professional development. Safeguarding arrangements are robust.

Areas for Improvement

Timely achievement rates remain below the national comparator for apprenticeships and are the principal focus of the 2024–25 Quality Improvement Plan. Functional Skills achievement rates, while above the sector average, have room for improvement and are addressed through targeted actions in the QIP.

Governance
Conflict of Interest Policy
Reviewed: September 2024 Next review: September 2025 Owner: Managing Director

1. Purpose

A conflict of interest arises when an individual's personal or financial interests could improperly influence their professional decisions and actions in their role at PLUMS Limited. This policy requires all staff to identify and manage conflicts of interest to maintain the integrity of our programmes and governance.

2. Declaration Requirements

All staff are required to declare any actual or potential conflicts of interest to their line manager and to the Managing Director as soon as they become aware of them. Declarations are recorded in the Conflicts of Interest Register maintained by the Managing Director.

3. Examples of Conflicts

  • A Skills Coach who has a personal relationship with an employer partner or learner
  • A member of staff involved in procurement who has a financial interest in a supplier
  • Any staff member involved in assessing a learner who has assessed them in a personal capacity previously

4. Managing Conflicts

Where a conflict is declared, the Managing Director will assess the nature of the conflict and put appropriate management measures in place, which may include reassignment of responsibilities, recusal from specific decisions, or other actions as appropriate.

5. Failure to Declare

Failure to declare a conflict of interest is a serious matter and will be addressed through the Disciplinary procedure.

People
Disciplinary & Grievance Procedure
Reviewed: September 2024 Next review: September 2025 Owner: HR / Managing Director

1. Disciplinary Procedure

PLUMS Limited follows the ACAS Code of Practice on Disciplinary and Grievance Procedures. The disciplinary procedure is designed to help employees improve rather than to punish, except in cases of gross misconduct.

2. Disciplinary Process

  1. Informal discussion: Minor performance or conduct issues are addressed informally in the first instance
  2. Formal investigation: If informal resolution fails or the matter is serious, a formal investigation is conducted by a manager with no involvement in the matter
  3. Disciplinary hearing: The employee is invited in writing to a formal hearing with at least 48 hours notice and may be accompanied by a colleague or trade union representative
  4. Decision and outcome: Possible outcomes include no action, a verbal warning, a first written warning, a final written warning, or dismissal
  5. Appeal: The employee may appeal any disciplinary decision within five working days to a more senior manager

3. Gross Misconduct

Examples of gross misconduct include theft, fraud, violence, serious harassment, safeguarding breaches and deliberate falsification of ESFA funding records. Gross misconduct may result in summary dismissal without prior warning following a proper investigation and hearing.

4. Grievance Procedure

Employees who have a grievance about their working conditions, treatment or any aspect of their employment should raise it informally with their line manager in the first instance. If unresolved, a formal grievance may be submitted in writing. The same process of investigation, hearing and appeal applies as outlined above.