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Policies

At QPS, we are committed to maintaining the highest standards of compliance with anti-money laundering (AML) regulations to safeguard against financial crime. This policy outlines our approach to identifying and reporting suspicious activities in line with current UK AML legislation and best practices.

  1. Understanding suspicious activities

 

Suspicious activities may involve transactions or behaviours that could indicate money laundering or financial crime. Key indicators include:

Unusual transactions:

  • Significant cash deposits or withdrawals inconsistent with a customer’s normal behaviour.
  • Repeated transactions just below regulatory thresholds.
  • Unexplained transfers to or from jurisdictions considered high-risk.

 

Customer behaviour:

  • Reluctance to provide required information or exhibiting unusually defensive conduct.
  • Use of multiple accounts with no clear business rationale.
  • Requests to bypass standard record-keeping procedures.

 

Complex financial arrangements:

  • Use of shell companies or offshore entities without valid justification.
  • Third-party involvement in transactions where no apparent link exists.
  • Transactions that lack commercial logic.

  1. Procedures for identifying suspicious activities

 

To effectively detect and address potential risks, the following measures are in place:

Know Your Customer (KYC):

  • Verify customer identities and understand their financial activity during onboarding and throughout the relationship.


Transaction monitoring:

  • Regularly review account activities to detect unusual patterns or deviations from expected behaviour.

 

Context evaluation:

  • Assess customer profiles, market conditions, and business operations when reviewing transactions.

 

Staff awareness:

  • Maintain up-to-date knowledge of AML trends, high-risk jurisdictions, and emerging financial crime methods.

 

  1. Reporting suspicious activities

When suspicious activities are identified, they must be promptly escalated and reported as follows:

 

Documentation:

  • Record all relevant transaction details, including amounts, dates, parties involved, and accompanying communications.
  • Clearly outline the reasons for suspecting illicit activity.

 

Internal notification:

  • Report suspicions immediately to QPS’s designated AML Compliance Officer, ensuring all supporting documentation is shared.

 

Submission of Suspicious Activity Reports (SARs):

  • The Compliance Officer will evaluate and, if necessary, submit a SAR to the relevant regulatory authority, such as the Financial Conduct Authority (FCA) in the UK.

 

Confidentiality:

  • It is strictly prohibited to disclose to the customer or any third party that a SAR has been filed or that their activities are under review.

 

  1. Ongoing responsibilities and training

To maintain an effective AML framework, QPS undertakes the following:

 

Regular training:

  • Provide employees with comprehensive training on recognising and reporting suspicious activities.

 

Policy updates:

  • Periodically review and revise AML policies to reflect changes in regulations and industry best practices.

 

Cooperation with authorities:

  • Offer full support to regulators and law enforcement during investigations and audits.

 

  1. Commitment to compliance and transparency

By identifying and addressing suspicious activities promptly, QPS complies with AML regulations and contributes to combating financial crime globally. If you encounter concerns or require guidance, escalate the issue to our Compliance Officer without delay.

For more information or assistance, please contact Matthew Ryan: [email protected]

1. Policy statement

QPS Group is committed to conducting all business activities with honesty, integrity and transparency.

We adopt a zero-tolerance approach to tax evasion and the criminal facilitation of tax evasion, whether under UK law or the law of any overseas jurisdiction in which we operate.

QPS Group recognises its responsibilities under the Criminal Finances Act 2017 and is committed to implementing and maintaining reasonable prevention procedures designed to prevent employees, workers, contractors, suppliers, agents and other associated persons from facilitating tax evasion.

Any employee, worker, contractor or associated person found to have facilitated tax evasion, or to have breached this policy, may be subject to disciplinary action, termination of engagement and, where appropriate, referral to the relevant authorities.

2. Purpose

The purpose of this policy is to:

  • Confirm QPS Group’s commitment to preventing the facilitation of tax evasion.
  • Define the responsibilities of employees and associated persons.
  • Establish procedures designed to prevent tax evasion facilitation.
  • Promote a culture of compliance and ethical conduct.
  • Ensure compliance with the Criminal Finances Act 2017 and other relevant legislation.

3. Scope

This policy applies to all individuals working for or on behalf of QPS Group, including:

  • Directors.
  • Employees.
  • Temporary workers.
  • Agency workers.
  • Contractors.
  • Consultants.
  • Suppliers.
  • Intermediaries.
  • Business partners.
  • Any other person performing services for or on behalf of QPS Group.

The policy applies across all QPS Group operations, including payroll services, umbrella employment, CIS administration, accountancy services, international workforce solutions and any future business activities.

4. What is tax evasion?

Tax evasion is the deliberate and dishonest underpayment, non-payment or concealment of tax liabilities.

Examples include:

  • Deliberately failing to declare taxable income.
  • Falsifying records submitted to HMRC.
  • Concealing income or gains.
  • Creating false documentation to reduce tax liabilities.
  • Misrepresenting employment status to avoid tax obligations.

Tax evasion is a criminal offence.

Tax avoidance, whilst subject to scrutiny by HMRC, is distinct from tax evasion and involves arranging affairs within the law to minimise tax liabilities.

5. What is the facilitation of tax evasion?

Facilitation of tax evasion occurs when a person deliberately and dishonestly assists another person to evade tax.

Examples may include:

  • Assisting with the creation of false records.
  • Knowingly processing payments designed to conceal taxable income.
  • Deliberately misrepresenting a worker’s status.
  • Helping another person hide income or assets from a tax authority.
  • Assisting with arrangements intended to avoid PAYE, National Insurance, VAT or CIS obligations.

Under the Criminal Finances Act 2017, an organisation can commit an offence if an associated person criminally facilitates tax evasion whilst acting on its behalf.

6. The six guiding principles

QPS Group has implemented reasonable prevention procedures based on HMRC’s Six Guiding Principles.

 

6.1 Risk assessment

QPS Group regularly assesses the risk of tax evasion and tax evasion facilitation across its operations.

Risk assessments consider:

  • Umbrella employment services.
  • CIS and self-employed engagements.
  • Payroll processing activities.
  • Recruitment supply chains.
  • International workforce arrangements.
  • Supplier relationships.
  • Client onboarding processes.
  • Geographic and sector-specific risks.

Risk assessments are reviewed annually or whenever significant changes occur within the business.

 

6.2 Proportionate risk-based procedures

QPS Group maintains controls proportionate to the nature, scale and complexity of its activities.

These controls include:

  • Employment status assessments.
  • Worker identity verification.
  • Right to Work checks.
  • Payroll approval processes.
  • HMRC reporting controls.
  • Supplier due diligence.
  • Segregation of duties.
  • Compliance monitoring.
  • Internal and external audits.

Additional controls may be introduced where elevated risks are identified.

 

6.3 Top level commitment

The Board and senior management are committed to preventing tax evasion and the facilitation of tax evasion.

The Managing Director has overall responsibility for ensuring compliance with this policy and fostering a culture of integrity and transparency throughout the organisation.

Senior management will:

  • Lead by example.
  • Promote ethical conduct.
  • Support compliance initiatives.
  • Investigate concerns promptly.
  • Ensure sufficient resources are available to manage compliance risks.

 

6.4 Due diligence

QPS Group undertakes appropriate due diligence on persons and organisations that perform services for or on behalf of the business.

Due diligence may include:

  • Identity verification.
  • Credit checks.
  • Company verification.
  • Review of professional accreditations.
  • Review of tax registrations.
  • Assessment of regulatory compliance.
  • Contractual reviews.

Enhanced due diligence may be undertaken where higher risks are identified.

 

6.5 Communication and training

QPS Group communicates this policy throughout the organisation and to relevant third parties.

This includes:

  • Employee induction training.
  • Periodic compliance briefings.
  • Policy availability through internal systems.
  • Supplier and partner communication.
  • Management guidance and support.

Employees and associated persons are expected to understand their responsibilities and comply with this policy at all times.

 

6.6 Monitoring and review

QPS Group regularly reviews the effectiveness of its prevention procedures.

This may include:

  • Internal audits.
  • Compliance reviews.
  • Investigation of reported concerns.
  • External accreditation assessments.
  • Legislative monitoring.
  • Policy reviews.

Any identified weaknesses will be addressed promptly through corrective action.

 7. Responsibilities

Every employee and associated person is responsible for:

  • Complying with this policy.
  • Remaining vigilant to potential risks.
  • Reporting concerns promptly.
  • Cooperating with investigations.
  • Completing any required training.

Failure to comply with this policy may result in disciplinary action or termination of business relationships.

 8. Prohibited conduct

No employee or associated person may:

  • Facilitate tax evasion.
  • Assist another person to evade tax.
  • Ignore suspected tax evasion.
  • Create or process false records.
  • Conceal information from HMRC or other tax authorities.
  • Deliberately misrepresent worker status.
  • Process payments designed to avoid tax liabilities.
  • Retaliate against anyone who raises a concern under this policy.

 9. Risk indicators and red flags

Employees should remain alert to circumstances that may indicate tax evasion risks.

Examples include:

  • Requests to pay workers gross without a legitimate basis.
  • Requests to suppress PAYE, National Insurance or CIS deductions.
  • Attempts to disguise earnings as loans, grants, advances or non-taxable payments.
  • Requests to alter invoices, payroll records or worker contracts.
  • Individuals seeking self-employed treatment where working arrangements indicate employment.
  • Requests for payments to unrelated third parties.
  • Offshore payment requests without a legitimate commercial rationale.
  • Refusal to provide identification or compliance documentation.
  • Requests to backdate contracts or payroll records.
  • False or inconsistent information provided during onboarding.
  • Requests to avoid HMRC reporting obligations.
  • Unusual payment structures lacking commercial justification.

Any concerns should be reported immediately.

 10. Reporting concerns

Employees and associated persons must report any actual or suspected breaches of this policy as soon as possible.

Concerns should be reported to:

Robert Arnold
Managing Director

or

Dan Newham
Operations Manager

Reports will be treated confidentially wherever possible and investigated appropriately.

QPS Group will not tolerate retaliation against any individual who raises a genuine concern in good faith.

 11. Training

Relevant employees will receive periodic training appropriate to their role and responsibilities.

Additional training may be provided to personnel operating within higher-risk areas, including:

  • Payroll.
  • Finance.
  • Compliance.
  • Accountancy.
  • Business development.
  • International workforce services.

 12. Breaches of the policy

Any breach of this policy by an employee may result in disciplinary action, up to and including dismissal.

QPS Group reserves the right to terminate relationships with contractors, suppliers, agencies or other third parties who breach this policy.

Where criminal conduct is suspected, QPS Group may report matters to HMRC, law enforcement agencies or other relevant authorities.

 13. Related policies

This policy should be read in conjunction with:

  • Anti-Money Laundering Policy.
  • Whistleblowing Policy.
  • Bribery and Corruption Policy.
  • Code of Conduct.
  • Data Protection Policy.
  • Supplier Due Diligence Procedures.
  • Compliance and Risk Management Framework.

14. Policy review

This policy will be reviewed annually, or sooner if required by legislative, regulatory or operational changes.

Our Corporate Social Responsibility (CSR) company policy outlines our efforts to be socially responsible, supporting the (local) communities in which we operate, and providing employees with opportunities for charitable work.

Our company’s social responsibility falls into two categories: compliance and proactiveness. Compliance refers to our company’s commitment to legality and willingness to observe community values. Proactiveness is every initiative to promote human rights, help communities and protect our natural environment.

Compliance

Legality

Our company will:

  • Respect the law
  • Honour its internal policies
  • Ensure that all its business operations are legitimate
  • Keep every partnership and collaboration open and transparent
  • Business ethics

We’ll always conduct business with integrity and respect for human rights. We’ll promote:

  • Safety and fair dealing
  • Respect
  • Anti-bribery and anti-corruption practices
Protecting the environment

Our company recognises the need to protect the natural environment. Keeping our environment clean and unpolluted is a benefit to all. We’ll always follow best practices when disposing garbage and using chemical substances. Stewardship will also play an important role.

Protecting people

We’ll ensure that we:

  • Don’t risk the health and safety of our employees and the community.
  • Support diversity and inclusion.
  • Human rights

Our company is dedicated to protecting human rights. We are a committed equal opportunity employer and will abide by all fair labour practices. We’ll ensure that our activities do not directly or indirectly violate human rights in any country (e.g. forced labour).

Proactiveness

Donations and aid

Our company may preserve a budget to make monetary donations. These donations will aim to:

Advance the arts, education and community events and alleviate those in need.

Volunteering

Our company will encourage its employees to volunteer. They can volunteer through programs organised internally or externally. Our company may sponsor volunteering events from other organisations.

Preserving the environment

Apart from legal obligations, our company will proactively protect the environment. Examples of relevant activities include:

  • Recycling
  • Conserving energy
  • Organising reforestation excursions
  • Using environmentally-friendly technologies
  • Supporting the community

Our company may initiate and support community investment and educational programs. For example, it may begin partnerships with vendors for constructing public buildings. It can provide support to non-profit organisations or movements to promote cultural and economic development of global and local communities.

Learning

We will actively invest in R&D. We will be open to suggestions and listen carefully to ideas. Our company will try to continuously improve the way it operates.

The Company maintains a commitment to monitor best practice and operate continuous improvement in our CSR policy.

All our team have the opportunity to involve themselves in their charitable passions.

Team members are regularly released from work in order to support their chosen charitable activities including bereavement counselling and school governor meetings.

Our CSR is ingrained throughout our organisation.

Quest Pay Solutions NE Limited T/A QPS Group

Brands: QPS Accountancy, QPS Payroll, QPS Financial, QPS Funding, and QPS Global

We are committed to providing exceptional service across all our brands. However, if we fall short of your expectations, we value your feedback and are dedicated to resolving any complaints promptly and fairly.

Scope of the Policy

This policy applies to complaints regarding:

  • Services provided directly by QPS Group.
  • Services facilitated through introductions to third parties in line with specific regulatory compliance.

 

How to Raise a Complaint

You can raise a complaint through any of the following channels:

Please provide as much detail as possible about your concern, including:

  1. The brand involved (e.g., QPS Accountancy, QPS Payroll).
  2. The nature of the issue.
  3. Relevant dates and supporting documents, if applicable.

 

Our Complaints Resolution Process

  1. Acknowledgement:
    • We will acknowledge your complaint on the same working day it is received.
  2. Initial Resolution:
    • A first-line agent will aim to resolve your query immediately or by the end of the working day.
  3. Escalation:
    • If the issue cannot be resolved at this stage, it will be escalated to the relevant Brand Manager for a detailed review.
    • You will be informed of the escalation and provided with the manager’s contact details.
  4. Investigation:
    • The Brand Manager will investigate the matter thoroughly and may contact you for additional information if needed.
  5. Response Timeframe:
    • We aim to resolve escalated complaints within 5 working days. In cases requiring more time, we will provide updates every 3 working days until the matter is resolved.
  6. Final Outcome:
    • Once a decision is made, we will provide a clear explanation of the outcome and any corrective actions taken.

Third-Party Introductions

For complaints regarding services facilitated through introductions to third parties, we will:

  • Liaise with the relevant third party to ensure your concerns are addressed.
  • Provide you with the contact details of the third party if needed for direct follow-up.

 

Further Escalation

If you remain dissatisfied after following our complaints process, you may have the right to escalate the matter to an external body, such as a professional regulatory authority. Details will be provided upon request.

Commitment to Improvement

Your feedback helps us improve. All complaints are logged and reviewed to identify trends and implement necessary changes to enhance our services.

Quest Pay Solutions NE Limited T/A QPS Group
Delivering excellence across all our brands.

1. Purpose

The purpose of this Policy is to ensure that necessary records and documents of The Company are adequately protected and maintained and to ensure that records that are no longer needed by The Company or are of no value are discarded at the proper time. This Policy is also for the purpose of aiding employees of The Company in understanding their obligations in retaining electronic documents – including e-mail, Web files, text files, sound and video files, PDF documents, and all Microsoft Office or other formatted files.

2. Policy

This Policy represents The Company’s policy regarding the retention and disposal of records and the retention and disposal of electronic documents. 

3. Administration

Attached as Appendix A is a Record Retention Schedule that is approved as the initial maintenance, retention and disposal schedule for physical records of The Company and the retention and disposal of electronic documents. We will make modifications to the Record Retention Schedule from time to time to ensure that it follows National legislation and includes the appropriate document and record categories for The Company; monitor legislation affecting record retention; annually review the record retention and disposal program, and monitor compliance with this Policy.

In addition, any retained information can only be used for the purpose for which it is stored. This is compliant with the Data Protection Act 2018 and the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) 

4. Suspension of Record Disposal In Event of Legal Proceedings or Claims

There are certain occasions when information needs to be preserved beyond any limits set out in the Policy. The Policy must be SUSPENDED relating to a specific customer or document and the information retained beyond the period specified in The Company’s Data Retention Schedule in the following circumstances:

Legal proceedings or a regulatory or similar investigation or obligation to produce information are known to be likely, threatened or actual.

A crime is suspected or detected.

Information is relevant to a company in liquidation or receivership, where a debt is due to The Company.

Information is considered by the owning unit to be of potential historical importance and this has been confirmed by the Administrator.

In the case of possible or actual legal proceedings, investigations or crimes occurring, the type of information that needs to be retained relates to any that will help or harm The Company or the other side’s case or liability or amount involved.

If there is any doubt over whether legal proceedings, an investigation or a crime could occur, or what information is relevant or material in these circumstances, the Administrator should be contacted and legal advice sought.

The Administrator shall take such steps as is necessary to promptly inform all staff of any suspension in the further disposal of documents.

5. Security of personal information

The Company will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

The Company will store all personal information on our secure (password- and firewall-protected) servers.

The Client should acknowledge that the transmission of information over the internet is inherently insecure and that The Company cannot guarantee the security of data sent over the internet.

The Client will be responsible for keeping their Username and Password used for accessing The Company’s website confidential; The Company will not ask for a password other than when needed to log in to our website.

6. Amendments

The Company may update this policy from time to time by publishing a new version.

This page should be checked occasionally to ensure that the policy remains relevant.

7.Applicability

This Policy applies to all physical records generated during The Company’s operation, including both original documents and reproductions. It also applies to the electronic documents described above.

This Policy was approved by the Board of Directors of The Company on 5th January 2018.

 

 

APPENDIX A RECORD RETENTION SCHEDULE

The Record Retention Schedule is organised as follows:

SECTION TOPIC

  1. Accounting and Finance
  2. Contracts
  3. Corporate Records
  4. Correspondence and Internal Memoranda
  5. Personal Information
  6. Electronic Records
  7. Grant Records
  8. Insurance Records
  9. Legal
  10. Miscellaneous
  11. Personnel Records
  12. Tax Records

1. ACCOUNTING AND FINANCE

Record Type and then Retention Period

  • Annual Audit Reports and Financial Statements:     Permanent
  • Annual Audit Records, including work papers and other documents that relate to the audit:  7 years after completion of the audit
  • Annual Plans and Budgets:    7 years
  • Bank Statements and Cancelled Cheques:  7 years
  • Employee Expense Reports:    7 years
  • Interim Financial Statements:    7 years

2. CONTRACTS

Record Type and then Retention Period

Contracts and Related Correspondence (including any proposal that resulted in the contract and all other supportive documentation):  7 years after expiration or termination

3. CORPORATE RECORDS

Record Type and then Retention Period

  • Corporate Records (minutes, signed minutes of the Board and all committees, record of incorporation, articles of incorporation, annual corporate reports):    Permanent
  • Licenses and Permits:    Permanent

4. CORRESPONDENCE AND INTERNAL MEMORANDA

General Principle: Most correspondence and internal memoranda should be retained for the same period as the document to which they pertain or support. For instance, a letter pertaining to a particular contract would be retained as long as the contract (7 years after expiration). It is recommended that records that support a particular project be kept with the project and take on the retention time of that particular project file.

Correspondence or memoranda that do not pertain to documents having a prescribed retention period should generally be discarded sooner. These may be divided into two general categories:

  1. Those pertaining to routine matters and having no significant, lasting consequences should be discarded within five years. Some examples include:
  • Routine letters and notes that require no acknowledgement or follow up, such as notes of appreciation, congratulations, letters of transmittal, and plans for meetings.
  • Form letters that require no follow up.
  • Letters of general inquiry and replies that complete a cycle of correspondence.
  • Letters or complaints requesting specific action that have no further value after changes are made or action taken (such as name or address change).
  • Other letters of inconsequential subject matter or that definitely close correspondence to which no further reference will be necessary.
  • Chronological correspondence files.
  • Please note that copies of interoffice correspondence and documents where a copy will be in the originating department file should be read and destroyed, unless that information provides reference to or direction to other documents and must be kept for project traceability.
  1. Those pertaining to non-routine matters or having significant lasting consequences should generally be retained permanently. 

5. RETAINING PERSONAL DOCUMENTS

  1. This Section sets out the data retention policies and procedure of The Company, which are designed to help ensure compliance with legal obligations in relation to the retention and deletion of personal information
  2. Personal information that is processed by The Company for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

Without prejudice to point 2 (above) The Company will usually delete personal data falling within the categories set out below at the date/time set out below:

Record Type and then Retention Period

  • Information about a computer and about visits to and use of this website (including an IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths:     2 years
  • Information provided when registering with our website (including email address): 2 years
  • Information provided when completing a profile on our website (including a name, gender, date of birth, interests and hobbies, educational details):     2 years
  • Information provided for subscribing to email notifications and/or newsletters (including a name and email address): Indefinitely or until the client chooses to ‘unsubscribe’
  • Information provided when using the services on the website, or that is generated during the use of those services (including the timing, frequency and pattern of service use): Indefinitely
  • Information relating to any subscriptions made (including name, address, telephone number, email address and sector sought): 2 years or until consent is withdrawn
  • Information posted to our website for publication on the internet: 5 years after post
  • Information contained in or relating to any communications sent through the website (including the communication content and metadata associated with the communication): 2 years following contact
  • Any other personal information chosen to be sent: 2 years following contact

Notwithstanding the other provisions of this Section, The Company will retain documents (including electronic documents) containing personal data:

(a) to the extent that The Company is required to do so by law;

(b) if The Company believes that the documents may be relevant to any ongoing or prospective legal proceedings;

(c) and to establish, exercise or defend The Company’s legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

(d) if explicit consent is given by the data subject. Consent is requested at least every 2 years from candidates seeking contract roles and at least every 12 months for candidates seeking permanent employment.

Each day The Company will run a database backup copy of all electronic data contained on The Company data centre, except for the one financial package. All other databases are in the cloud, connected to a Tier 3 data centre. This backup will include all information relating to current users, as well as any information that remains due to any reason contained in this policy.

6. ELECTRONIC DOCUMENTS

  1. Electronic Mail: Not all email needs to be retained, depending on the subject matter.
  • All e-mail—from internal or external sources – is to be deleted after 12 months.
  • Staff will strive to keep all but an insignificant minority of their e-mail related to business issues.
  • The Company will archive e-mail for 90 days after the staff has deleted it, after which time the e-mail will be permanently deleted.
  • Staff will take care not to send confidential/proprietary information held by The Company to outside sources
  • Any e-mail staff deems vital to the performance of their job should be copied to the relevant client or candidate record in DataStar. (The Company CRM system).
  1. Electronic Documents: including Office 365 and PDF files, retention also depends on the subject matter.

The Company does not automatically delete electronic files beyond the dates specified in this Policy. It is the responsibility of all staff to adhere to the guidelines specified in this policy.

In certain case’s a document will be maintained in both paper and electronic form. In such cases, the official document will be the electronic document.

 

7. INSURANCE RECORDS

Record Type and then Retention Period

  • Certificates Issued to The Company    Permanent
  • Claims Files (including correspondence, medical records, etc.)    Permanent
  • Insurance Policies (including expired policies)    Permanent

 

8. LEGAL FILES AND PAPERS

Record Type and then Retention Period

  • Legal Memoranda and Opinions (including all subject matter files):  7 years after close of matter
  • Litigation Files:    1 year after expiration of appeals or time for filing appeals
  • Court Orders: Permanent

9. MISCELLANEOUS

Record Type and then Retention Period

  • Material of Historical Value (including pictures, publications):    Permanent
  • Policy and Procedures Manuals – Original:    Current version with revision history
  • Annual Reports:     Permanent

10. PERSONNEL RECORDS

Record Type and then Retention Period

  • Employee Personnel Records (including individual attendance records, application forms, job or status change records, performance evaluations, termination papers, withholding information, garnishments, test results, training and qualification records):    6 years after separation
  • Employment Contracts – Individual:    6 years after separation
  • Employment Records Correspondence with Employment Agencies and Advertisements for Job Openings:    3 years from date of hiring decision

11. TAX RECORDS

General Principle: The Company must keep books of account or records as are sufficient to establish amount of gross income, deductions, credits, or other matters required to be shown in any such return.

These documents and records shall be kept for as long as the contents thereof may become material in the administration of state, and local income, franchise, and property tax laws.

Record Type and then Retention Period

  • Tax-Exemption Documents and Related Correspondence:    Permanent
  • Tax Bills, Receipts, Statements:    7 years
  • Tax Returns:    Permanent
  • Sales/Use Tax Records:    7 years
  • Annual Information Returns:    Permanent

The Company recognises that its activities impact upon the environment through its routine internal operations, its infrastructure and through its influence and effects on the wider community. It acknowledges a responsibility for, and a commitment to, protection of the environment at all levels. The organisation will comply fully with environmental legislation and is in addition committed to continued efforts to:

  • Promote environmental management policies and practices at every level throughout the business
  • Increase awareness of environmental responsibilities among staff
  • Minimise waste and pollution and develop and operate environmentally sound waste management procedures
  • Reduce water and energy consumption
  • Promote a purchasing policy which will give preference, as is feasible, to those products and services which cause the least harm to the environment
  • Avoid wherever practical the use of environmentally damaging substances, materials and processes

Commitment to diversity

The Company embraces diversity and aims to promote the benefits of diversity in all of our business activities. We seek to develop a business culture that reflects that belief. We will expand the media in which we recruit to ensure that we have a diverse employee and candidate base. We will also strive to ensure that our clients meet their own diversity targets.

The Company is committed to diversity and will promote diversity for all employees, workers, and applicants. We will continuously review all aspects of recruitment to avoid unlawful discrimination. The Company will treat everyone equally and will not discriminate on the grounds of an individual’s “protected characteristic” under the Equality Act 2010 (the Act), which are age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation. We will not discriminate on the grounds of an individual’s membership or non-membership of a Trade Union.

All staff have an obligation to respect and comply with this policy. The Company is committed to providing training for its entire staff in equal opportunities and diversity.

The Company will avoid stipulating unnecessary requirements which could exclude a higher proportion of a particular group of people and will not prescribe discriminatory requirements for a role. The Company will not discriminate unlawfully when deciding which candidate or temporary worker is submitted for a vacancy or assignment, or in any terms of employment or engagement. Each candidate will be assessed on merit, qualifications, and ability to perform the relevant duties.

 

Discrimination

Direct discrimination

Direct discrimination occurs when an individual is treated less favourably because of a protected characteristic. Treating someone less favourably means treating them badly in comparison to others that do not have that protected characteristic.

It is unlawful for a recruitment consultancy to discriminate against a person on the grounds of a protected characteristic:

  • 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 can take place even if the individual does not have the protected characteristic but is treated less favourably because it is assumed he or she has the protected characteristic or is associated with someone who has.

Direct discrimination would also occur if a recruitment consultancy accepted and acted upon instructions from an employer which states that certain persons are unacceptable due to a protected characteristic, unless an exception applies.

The Act permits specifying a requirement that an individual must have a particular protected characteristic in order to undertake a job. These are known as occupational requirements. The client must show that applying the requirement is a proportionate means of achieving a legitimate aim.

 

Indirect discrimination

Indirect discrimination occurs when a provision, criterion, or practice (PCP) is applied but results in people who share a protected characteristic being placed at a disadvantage compared with those who do not. If the PCP can be objectively justified, it will not amount to discrimination.

Indirect discrimination would also occur if a recruitment consultant accepted and acted upon an indirectly discriminatory instruction from an employer.

Where a vacancy requires characteristics which amount to an occupational requirement or the instruction is discriminatory but objectively justified, The Company will not proceed unless the client provides written confirmation of the requirement or justification.

The Company will use best endeavours to comply with the Act and will not accept instructions from clients that would result in unlawful discrimination.

 

Harassment

Under the Act, harassment is defined as unwanted conduct related to a protected characteristic which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating, or offensive environment. This includes unwanted conduct of a sexual nature.

The Company is committed to providing a work environment free from unlawful harassment.

Examples of prohibited harassment include:

  1. Verbal or written conduct containing derogatory jokes or comments.
  2. Slurs or unwanted sexual advances.
  3. Visual conduct such as derogatory or sexually orientated posters.
  4. Photographs, cartoons, drawings, or gestures which some may find offensive.
  5. Physical conduct such as assault, unwanted touching, or interference based on sex, race, or other protected characteristic.
  6. Threats or demands to submit to sexual requests as a condition of continued employment or to avoid some other detriment, and offers of benefits in return for sexual favours.
  7. Retaliation for reporting or threatening to report harassment.

If an individual believes they have been unlawfully harassed, they should report the matter to The Company and follow up with a written complaint. Details should include the incident, the individuals involved, and any witnesses. The Company will investigate thoroughly and take remedial action where necessary.

All employees and workers must comply with this policy. Any breach will result in disciplinary action, up to and including termination.

 

Workers protection (amendment of equality act) 2010 – sexual harassment

From 26 October 2024, the Workers Protection (Amendment of Equality Act) 2010 introduced a new preventative duty on employers and employment businesses to take reasonable steps to protect workers from sexual harassment.

As an umbrella payroll provider, The Company does not oversee the day-to-day workplace environments where workers carry out their assignments. However, we remain committed to protecting workers from harassment and ensuring there are clear reporting channels and safeguards in place.

 

Definition

Sexual harassment is unwanted conduct of a sexual nature that has the purpose or effect of violating a person’s dignity, or creating an intimidating, hostile, degrading, humiliating, or offensive environment. It may be verbal, non-verbal, physical, or written, including online conduct.

 

Reporting process

Workers engaged through The Company who believe they have been subjected to sexual harassment should follow the process below:

  1. Report the incident – Contact the company’s Compliance team at [email protected]
  2. Provide details – Submit a written statement including details of the incident(s), individuals involved, witnesses, dates, and locations.
  3. Investigation – The Company will:
    • acknowledge receipt of the complaint,
    • liaise with the worker and, where necessary, the supplying recruitment agency and/or end client,
    • investigate thoroughly and impartially, and
    • take appropriate remedial action, including escalation to the client or regulator if necessary.
  4. Outcome – The worker will be kept updated and informed of the outcome.

 

Protection against victimisation

No worker will suffer detriment for raising a genuine complaint of harassment. Retaliation is strictly prohibited.

Responsibilities

  • The Company will maintain reporting procedures and respond promptly to concerns.
  • Recruitment agencies and end clients remain responsible for maintaining safe working environments.
  • Workers are encouraged to report incidents promptly so action can be taken.

This section will be reviewed annually in line with legislative developments and guidance from the Equality and Human Rights Commission (EHRC).

 

Victimisation

Victimisation occurs when an individual is treated unfavourably because they have carried out a ‘protected act’, such as bringing a claim for unlawful discrimination, raising a grievance, or giving evidence in respect of a complaint. The Company will ensure that consultants do not victimise any individual.

 

Disabled persons

The Company will make reasonable adjustments in recruitment and selection to ensure disabled applicants and workers are not placed at a disadvantage. Adjustments may include modifying procedures, interview arrangements, or providing additional support. The Company will not discriminate against disabled persons in any terms of recruitment, engagement, or ongoing employment.

 

Age discrimination

It is unlawful to discriminate, harass, or victimise a person because of age. The Company will encourage clients to recruit based on competence and skills rather than age and will ensure that age is not used unlawfully in any part of the recruitment or engagement process.

 

Part-time workers

The Company will treat part-time employees and workers on the same terms as full-time employees, on a pro-rata basis where appropriate. This includes pay, holiday entitlement, training, redundancy, and access to benefits.

 

Gender reassignment

The Company supports any employee or worker undergoing gender reassignment and will make every effort to protect them from discrimination or harassment. Alternative roles will be considered where genuine operational issues arise.

 

Recruitment of ex-offenders

Where The Company uses the Disclosure and Barring Service (DBS), we will comply with the DBS Code of Practice regarding the recruitment of ex-offenders.

 

Complaints and monitoring

The Company has procedures in place for monitoring compliance with this policy and for dealing with complaints of discrimination or harassment. Any complaint will be investigated fully and appropriate action taken.

Grievance procedure – PAYE employees

  1. Introduction

1.1

QPS is committed to maintaining a fair, professional and supportive working environment for all employees. We recognise that employees may occasionally wish to raise concerns relating to their employment, assignment or treatment whilst engaged through QPS.

1.2

The purpose of this procedure is to ensure that grievances are dealt with fairly, consistently and without unreasonable delay.

1.3

This procedure applies to:

  • Umbrella PAYE employees
  • Outsourced PAYE employees
  • Any other PAYE-employed temporary workers engaged by QPS

1.4

This procedure does not apply to:

  • CIS subcontractors
  • PSC/Limited company contractors
  • genuinely self-employed workers

Concerns raised by self-employed contractors will be managed separately through the appropriate operational or compliance process.

1.5

Examples of grievances may include:

  • pay queries or deductions
  • holiday pay concerns
  • timesheet disputes
  • workplace treatment
  • discrimination, bullying or harassment
  • health and safety concerns
  • working conditions
  • onboarding or compliance concerns
  • breaches of company policy or contractual terms

1.6

QPS aims to:

  • investigate formal grievances appropriately
  • provide employees with an opportunity to explain their concerns
  • communicate decisions clearly and in writing
  • provide a right of appeal where appropriate

1.7

This procedure does not form part of any contract of employment and may be amended by QPS at any time.

 

  1. Using this procedure

2.1

This procedure should not be used to appeal disciplinary action or dismissal decisions. Separate disciplinary and appeal procedures apply in these circumstances.

2.2

QPS also maintains separate procedures relating to:

  • whistleblowing
  • sexual harassment
  • equality and discrimination
  • safeguarding and modern slavery concerns

Employees should refer to the appropriate policy where relevant.

2.3

Grievances should be raised promptly. Unreasonable delays may affect QPS’s ability to investigate matters fully and fairly.

2.4

Where employment has ended, QPS reserves the right to respond to grievances in writing without holding a formal meeting.

 

  1. Informal resolution

3.1

QPS encourages employees to raise concerns informally wherever possible. Many issues can be resolved quickly through discussion and clarification.

3.2

Employees may raise concerns informally with:

  • payroll support
  • onboarding or compliance teams
  • HR
  • worker support representatives
  • an appropriate QPS manager

3.3

If the matter cannot be resolved informally, the employee may raise a formal grievance under this procedure.

 

  1. Formal grievances

4.1

Formal grievances should be submitted in writing to HR or an appropriate QPS representative.

4.2

The written grievance should include:

  • confirmation that it is a formal grievance
  • a summary of the concern
  • relevant dates, facts and details
  • names of any individuals involved
  • supporting evidence where available
  • the outcome sought

4.3

QPS may request additional information where necessary to support the investigation process.

4.4

Meetings held under this procedure must not be covertly recorded. Unauthorised recordings may be treated as misconduct.

 

  1. Investigations

5.1

QPS may carry out an investigation into any grievance raised.

5.2

The nature and extent of the investigation will depend on the circumstances of the matter raised.

5.3

Investigations may include:

  • reviewing payroll or assignment records
  • reviewing communications or compliance documentation
  • obtaining witness statements
  • discussions with recruitment agencies, clients or internal departments
  • meetings with the employee concerned

5.4

Employees are expected to cooperate fully with any investigation.

 

  1. Grievance meetings

6.1

Where appropriate, QPS will arrange a grievance meeting to discuss the matter further.

6.2

Meetings will normally be arranged within a reasonable timeframe following receipt of the formal grievance.

6.3

Employees may request to be accompanied by:

  • a work colleague
  • a trade union representative
  • another reasonable companion where appropriate

6.4

Meetings may be conducted in person, by telephone or by video conference.

6.5

The purpose of the meeting is to:

  • understand the grievance fully
  • allow the employee to explain their concerns
  • review relevant evidence
  • identify any potential resolution

6.6

Additional meetings or investigations may be carried out where appropriate.

6.7

QPS will aim to communicate the outcome in writing within a reasonable timeframe following completion of the investigation.

The written outcome will normally include:

  • the decision reached
  • a summary of the findings
  • any action to be taken
  • details of the right of appeal

 

  1. Appeals

7.1

If an employee is dissatisfied with the outcome, they may appeal in writing within 5 working days of receiving the decision.

7.2

The appeal should clearly explain:

  • the grounds of appeal
  • why the original decision is disputed
  • any additional supporting information

7.3

Where possible, appeals will be reviewed by a manager or representative not previously involved in the matter.

7.4

An appeal meeting may involve:

  • a review of the original decision; or
  • a full rehearing of the grievance

depending on the circumstances.

7.5

Following the appeal, the original decision may be:

  • upheld
  • amended
  • revoked
  • replaced with an alternative outcome

7.6

The appeal decision will be confirmed in writing and will be final.

 

  1. Additional information

8.1

QPS will treat grievances seriously and handle matters sensitively and confidentially wherever reasonably practicable.

8.2

Employees will not suffer detrimental treatment for raising a genuine grievance in good faith.

8.3

However, malicious, vexatious or knowingly false allegations may result in disciplinary action.

8.4

Operational changes, assignment changes or assignment endings for commercial or client reasons do not automatically constitute disciplinary action or a grievance outcome.

8.5

This procedure should be read alongside all other relevant QPS policies and procedures available on the QPS website or upon request.

It is an important duty of The Company, in the conduct of its business operations, to ensure a safe and healthy working environment for all its employees. The organisation accepts the fact that this implies a corresponding duty of ensuring that necessary organisation, equipment, and instruction is provided to fulfil this obligation. An effective health and safety policy requires the full collaboration and co-operation of all employees; everybody is asked to read this policy and accept their own personal responsibility for health and safety at work. The objectives of this policy are fundamental to our business and the Company Directors are responsible for ensuring that the requirements of this policy are achieved.

The Company is committed to operating the business in accordance with the Health and Safety at Work Act 1974 and all applicable regulations made under the Act, as far as reasonably practicable.

  • Risk assessments are to be completed by the brand manager/director to assess the office environment to ensure our workplaces are safe for our workers. Completed risk assessments are sent to the Group’s head office for central collation and record keeping.

  • Provide and maintain facilities, equipment, and systems of work that are safe and without risks to health.

  • Provide such information, instruction supervision as is necessary to ensure the health and safety at work of employees and visitors.

  • Maintain any place of work under the Company’s control in a condition that is safe and without risks to health and to provide and maintain means of access to and egress from it that are safe and without such risks.

  • Provide and maintain a working environment for employees that is safe and without risks to health and is adequate as regards facilities and arrangements for their welfare at work.

  • Encourage staff to set exacting standards of health and safety by personal example and to instill an attitude of mind which accepts good health and safety practice as normal.

  • Monitor the effectiveness of health and safety provisions within The Company.

  • Keep the Health & Safety Policy under regular review and to duly publish any amendments.

Management and staff have responsibility for implementing the specific arrangements made under this policy throughout the Company. All employees are expected to familiarise themselves with its provisions and fulfil their defined responsibilities, a copy of all related policies will be held in the HR department and will be made available to all employees.

This policy will be audited for its effectiveness on a regular basis.

Health & Safety Statement from the CEO

The Company regards the management of health and safety as an integral part of its business and as a management priority. It is our policy that all activities and work will be conducted in a safe manner, and we will ensure the health, safety and welfare of our employees and others who may be affected by our activities.

Proper management of health and safety issues is seen as an integral part of the efficient management of the Company’s activities, and critical to developing the professional culture of the Company and establishing and maintaining a solid reputation with all our customers.

The Company is committed to ensure the health, safety & wellbeing of all staff in line with government guidance and legislation.

Organisation

Ultimate responsibility for Health & Safety rests with The Company and its team of directors. The HR Director has specific responsibility for overseeing the implementation of Health & Safety policy and for advising and updating the Board of The Company and CEO on developments and performance.

All employees, contractors and sub-contractors are required to cooperate with the Company and their colleagues in implementing the policy and shall ensure that their own work is without risks to themselves and others as far as reasonably practicable. And to be proactive on health and safety issues as part of the continued development of the health and safety culture of the organisation.

Directors

The Company’s directors have responsibility for implementation of the Health & Safety Principles and Policy in their areas of responsibility. They must show leadership by ensuring the organisation, management and conduct of operations is in line with The Company standards and ensuring this is supported by adequate resource allocation to implement this policy across the business.

All employees have the responsibility to co-operate with the directors and management to achieve a healthy and safe workplace and to take reasonable care of themselves and others.

Whenever an employee notices a health or safety problem which they are not able to put right, they must straightaway inform a member of the Health & Safety Committee.

Managers

Managers have responsibility for the health, safety and wellbeing of those working within their area of operation and those who may be affected by the activities. They must ensure that adequate systems are in place to ensure delivery of policy and standards and meet local statutory requirements.

Those tasked with the supervision of staff, at whatever level, are required to give careful attention to the health and safety of those under their supervision and to ensure that appropriate precautions are taken.

To fulfil its function, the degree of supervision must have reasonable regard to the level of training, experience and expertise of employees being supervised.

The responsibilities of manager(s) within the company shall be:

  • To read and understand the company’s safety policy and to ensure that its provisions are being effectively conducted.
  • To bring the provisions of this policy, as far as they affect the personnel, to the attention of the employees under the control of managers/supervisors.
  • To inspect machinery, equipment and structures regularly and to ensure that any defects discovered are remedied forthwith.
  • To prevent access by the workforce or other persons to any defective equipment or structures until the faults have been rectified.
  • To ensure that employees are adequately instructed in the safe operation of equipment and machinery.
  • To ensure that any areas of the site to which the public or visitors may have access, are maintained to ensure their safety.
  • To arrange for all necessary insurances, certificates etc., appropriate to the site’s size and function.
  • To arrange via the responsible person for the reporting of all incidents to the insurers where appropriate.
  • To arrange the appropriate fire-certificates for each site, the proper maintenance of firefighting equipment, regular fire drills and adequate access to fire-fighting services.
  • Ensure that adequate first-aid facilities are available and adequately maintained.
  • To ensure that all accidents are reported in accordance with the provision of this policy.
  • Ensure that no unnecessary risks are taken by the employees in pursuance of their duties and to ensure a site disciplinary procedure is in place for offenders.
  • Set a personal example.
  • To give advice upon this policy when requested by either the directors or workforce.

Individuals

Individual employees have a duty to conduct their work in a safe manner to prevent injury and ill health either to themselves or to others who may be affected by their acts or omissions at work.

Individuals are required to comply with the Company’s Health and Safety Policy as it relates to their work activities, and to any action to be taken in case of an emergency.

Amendments

Any amendments will be notified by revision of this document.

Quest Pay Solutions T/A QPS Group is a subsidiary company of Bluestones Investment Group Limited.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Group’s slavery and human trafficking statement for the financial year ending 31 October 2024. This Statement has been approved by the Board of Directors of Bluestones Investment Group Limited (Bluestones).

 

Operating primarily in the UK, Bluestones employs over 394 people across 29 locations. Bluestones is a human capital investment company, with the subsidiary businesses within it’s portfolio being made up of recruitment businesses, staffing service companies and related workforce solutions providers.

 

References to the Bluestones Group mean Bluestones and its subsidiary companies. Further information about the Bluestones Group and information on our subsidiary companies is available on the Group website HERE.

 

This statement applies to the Bluestones Group and its subsidiary companies.

 

Modern Slavery Statement

The Bluestones Group does not believe there is any place in today’s world for slavery and human trafficking and in making this statement commits to ensuring there is no modern slavery or human trafficking in our supply chains or in any part of our businesses.

 

We are committed to evolving our practices through all our group companies to combat slavery and human trafficking and to encourage the same principles and standards from our supply chain and business partners.

 

No breaches of the Modern Slavery Act 2015 were reported in the Bluestones Group in FY 2024 or have been previously.

 

 

The ways in which the Bluestones Group are minimising the risks of modern slavery are details below.

 

Our Supply Chain

The Bluestones Group takes its responsibility for ensuring the risk of modern slavery and human trafficking is minimised across its supply chain. It achieves this through a combination of supplier due diligence questionnaires and annual supplier audits. The Group expects its staff to report concerns of non-compliance, no matter how trivial, in line with the established policies and procedures.

 

Due diligence processes

In order to identify and mitigate the risks associated with modern slavery and human trafficking, the Bluestones Group has adopted the following processes:

 

  1. We review our supplier appraisal questionnaires on an annual basis to ensure continued compliance. Ensuring the questionnaire includes unambiguous questions regarding a supplier’s compliance (with modern slavery and human trafficking legislation) and their policies and processes)

 

  1. We conduct internal audits on our recruitment process (and those of our subsidiaries) to ensure that we only engage eligible workers for agency work.

 

  1. We expect the suppliers we work with to have anti-slavery and human trafficking policies and processes that cover the subsequent relationships with their suppliers as it is not practical for us to influence and have a direct relationship with all levels of the supply chain.

 

Risk assessment

With many of the subsidiary companies within the Bluestones Group placing personnel into companies on a temporary, contract or permanent basis, we appreciate the importance of robust operational practices. Through the aforementioned due diligence processes, supplier audits and questionnaires, and internal policies and staff training, we act to minimise the risk of individuals being placed into any form of slavery.

 

Checks are also undertaken to verify and identify where agency workers may be sharing bank accounts, addresses and telephone numbers which may be a risk indicator.

 

Bluestones will continue to assess the risks associated with modern slavery and human trafficking and aim to fully understand other indicators of modern slavery.

 

Measuring effectiveness

Through regular monitoring, audits and assessments we measure the effectiveness of our risk control measures to ensure that slavery and human trafficking is not taking place in our business, our subsidiary businesses or our supply chains.

 

Our key performance indicators (KPIs) in this instance are:

 

  • 100% compliance of supply chain companies via the supply chain audit process.
  • 100% pass rate when reviewing recruitment activities and their compliance with agreed modern slavery processes.

 

Policies on modern slavery

Bluestones Investment Group has a clearly defined Modern Slavery Policy, which can be read in full in this policies section of the website. This policy is regularly updated to reflect best practice methodologies.

 

Our Modern Slavery Policy reflects the Company’s commitment to acting with integrity in all its relationships and has implemented adequate policies, procedures and systems to ensure that slavery and human trafficking is not taking place.

 

Training for staff

With such a clear focus on maintaining 100% compliance with modern slavery and human trafficking legislation it is essential that the people within our business receive adequate training and information. We provide information on this legislation and our policies and processes via the Group’s Intranet system and through induction and training updates.

 

Employees, workers, business partners and customers are encouraged to report any concerns that may give rise to a risk of modern slavery or human trafficking. The Group’s Whistleblowing Policy is designed to make it easy for disclosures to be made without fear of retaliation. The Group’s Legal & HR Director, a practising solicitor, is the Whistleblowing Officer. In circumstances which prevent independent consideration of disclosures internally the Company’s auditors or external solicitors will be instructed.

 

Employees are advised on how to report any concerns they have associated with modern slavery and trafficking.

This Privacy Notice tells you what to expect in relation to personal information about you which is collected, handled and processed by The Company .

The Company’s Human Resources function is the Data Controller.

We acknowledge and agree that any personal data of yours that we handle will be processed in accordance with all applicable data protection laws in force from time to time.  With effect from 25 May 2018, the General Data Protection Regulations (“GDPR”) will come into force, which will change the law.

The information about you we may collect, hold and process is set out below:

(a) Information collected and processed for finding you a suitable role is as follows:

  • Your name
  • Your address
  • Your email address
  • Your telephone number
  • CV/work history
  • Job preferences including role, geographical areas and salary
  • Any other work related information you provide, for example, education or training
  • Inbound and outbound calls are recorded for training and monitoring purposes

(b) Information in respect to individuals that have worked for us previously or may work for us is as follows:

  • Passport (if applicable, permits and visas)
  • Date of Birth
  • National Insurance Number
  • Full detail of job offers and placements
  • Outcome of DBS and security clearance for certain roles (these will be supplied by the Disclosure and Barring Service or other external company applicable to the placement.
  • Medical information (in specified cases – medical information may be supplied by a third party such as your GP, Consultant or Occupational Health)
  • References (these will be from your previous employer or personal references as appropriate).
  • Financial information (including but not limited to payroll details and terms, HMRC data, pension scheme details, court orders and statutory payments)
  • A log of our communications with you by email and telephone
  • Inbound and outbound calls are recorded for training and monitoring purposes

This information will have been provided, or will be provided, by you or a third party who we work with, such as a Job Board Company or another employment business or agency.

How we use the information

The above information is used to provide our services to you in our capacity as an employment business / agency to find you suitable work whether on a temporary or permanent basis based on your requirements as set out below.

The information under A above may be used as follows:

  • To match your skill sets with job vacancies to assist in finding you the positions that best match your expertise.
  • To put forward your details to our clients and prospective employers for you to be considered for vacancies.
  • To place you with our clients and prospective employers
  • To keep you informed for available opportunities as they arise
  • To keep you informed of the services offered by us

The information under B above may be used as follows:

  • To establish that you have the right to work
  • To undertake relevant security and DBS checks as required by our clients and as permitted by law.
  • To deal with any medical and health and safety issues relating to specific positions
  • To put in place contractual arrangements and documentation once a role has been secured
  • To pay you if we find you work

How we hold the information

All the personal data we have is stored on our database in the UK.

Disclosure of your information

  • Your CV and related information will be shared or sent to prospective employers and our clients. Once you have secured a placement additional information will be provided to them to enable the placement to proceed.
  • Such employers and clients will usually be located inside the European Economic Area (EEA) but may be outside of the EEA.
  • Personal data shall not be transferred to a country or territory outside the EEA unless that country or territory ensures an adequate level of protection or the appropriate safeguards are in place for your rights and freedoms.  Before such a transfer takes place outside of the EEA, we will provide you with further information concerning this.
  • Other trusted third parties that we may share your data with are as follows: pension scheme providers, HM Revenue and Customs, Umbrella companies, legal advisors and other companies for the purpose of undertaking pre engagement checks for the role or for paying you.

What is the legal basis for processing the information?

We will rely on your consent to process the information marked with an * above which is collected at the outset of the recruitment process.

Information and documentation to establish your right to work is processed by us as we are legally obliged to do so.

In respect of medical information, the basis for us processing this will depend on the circumstances, but will usually be for one of the following reasons: it is necessary to protect health and safety within the work environment or to prevent discrimination on the grounds of disability or where consent has been obtained, if required.

Information in relation to criminal record checks, which are relevant for some roles, will be processed on the basis that it is necessary for us to comply with the law or consent will be obtained, if required.

Once a position has been found for you, we will process your personal data, including financial information, for the purpose of you entering into a contract to fulfil your role and to enable us to pay you, depending on the specific contractual arrangements and circumstances.

For the purposes of paying you, where relevant, we are legally obliged to provide information to HMRC.

Once a placement has been secured, we may also process your data on the basis of our legitimate interests i.e. for administrative purposes.

Your rights

You currently have the right at any time to ask for a copy of the information about you that we hold in addition to your right to be forgotten. If you would like to make a request for information please go to our website.

Retention of your data

Your data will be retained for no longer than is necessary and in accordance with our Data Retention Policy.

Withdrawal of consent

If you have provided us with your consent to process your data, for the purpose of using our services and us finding you suitable work, you have the right to withdraw this at any time.  In order to do so you should contact us via the website.

Concerns

If you have a concern about the way we are collecting or using your personal data, you should raise your concern with us in the first instance or directly to Information Commissioners Office at
https://ico.org.uk/concerns

Cookies

During the course of any visit to The Company’s website, the pages you see, along with a short text file called a ‘cookie’, are downloaded to your computer. Many websites do this, because cookies enable website publishers to do useful things like find out whether you have visited the website before.

A cookie is a small amount of data, which often includes an anonymous unique identifier that is sent to your browser from a website’s computer and stored on your computer’s hard drive. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a web site to access the cookies it has already sent to you, not the cookies sent to you by other sites. Cookies record information about your online preferences. Users have the opportunity to set their computers to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time.

Call Recording Policy

Please be advised that telephone calls to and from our business may be recorded for training, monitoring, quality assurance and transcription purposes. The transcription is to capture call summary and actions.

Contact

Please address any questions, comments and requests regarding our data processing practices to Human Resources.

Changes to the Privacy Notice

This Privacy Notice may be changed by us at any time.

Right to Work (RTW) Verification Policy

  1. Purpose

The purpose of this policy is to ensure that Quest Pay Solutions NE Ltd (“QPS”) complies with all legal obligations relating to the prevention of illegal working under the Immigration, Asylum and Nationality Act 2006 and associated Home Office guidance.

QPS will undertake Right to Work (RTW) checks on all workers prior to engagement and maintain appropriate records throughout the duration of the engagement to establish and retain a statutory excuse against civil penalties.

No worker may commence work until a satisfactory Right to Work check has been completed and verified.

 

  1. Scope

This policy applies to:

  • All prospective workers in the process of onboarding through QPS
  • Existing workers whose Right to Work status is time-limited
  • Employees, agency workers, umbrella workers, CIS workers and any other individuals engaged through QPS

 

  1. General Principles

QPS will:

  • Conduct RTW checks before work commences.
  • Verify that all documents and information appear genuine and relate to the individual presenting them.
  • Obtain evidence confirming the identity of the worker.
  • Retain RTW records securely in accordance with data protection legislation.
  • Monitor and re-check time-limited permissions before they expire.
  • Follow Home Office guidance and approved verification methods.

Where available, QPS will utilise digital verification systems approved for Right to Work checking.

 

  1. British and Irish Citizens Holding a Valid Passport

Where a worker holds a valid British or Irish passport, QPS will conduct a digital RTW check using TrustID.

The worker must:

  1. Provide a live image of their passport.
  2. Provide a live facial image (“selfie”) for comparison.

A successful TrustID verification will be accepted as evidence of the individual’s Right to Work.

No further documentation will normally be required where the TrustID check is successfully completed.

 

  1. British and Irish Citizens with an Expired Passport

Where a worker holds an expired British or Irish passport, QPS will conduct a manual RTW check.

The worker must provide:

  • A copy of the expired passport.
  • A copy of an alternative current photographic identification document (typically a UK driving licence).
  • A facial image (“selfie”) for comparison.

QPS will review the documentation to confirm identity and retain copies on file.

 

  1. British and Irish Citizens Without a Passport

Where a worker does not possess a valid British or Irish passport, QPS will conduct a manual RTW check using acceptable List A documentation.

The worker must provide:

  • A full birth certificate issued in the United Kingdom, Channel Islands, Isle of Man or Ireland.
  • Evidence of their National Insurance number, such as:
    • A payslip;
    • A P45;
    • A P60; or
    • An official government document displaying the National Insurance number.
  • A current photographic identification document (typically a UK driving licence).
  • A facial image (“selfie”) for comparison.

QPS will verify that the documents relate to the individual and retain copies on file.

 

  1. Non-British and Non-Irish Nationals

Workers who require immigration permission to work in the United Kingdom must provide evidence of their immigration status before engagement.

Where available, workers should provide a Home Office Share Code.

The Share Code may be:

  • Entered directly into the TrustID platform by the worker; or
  • Supplied to QPS together with a current selfie photograph for manual verification through the Home Office online checking service.

QPS will review the Home Office verification result and retain evidence of the check.

Examples of individuals who may provide a Share Code include:

  • Skilled Worker visa holders.
  • Health and Care Worker visa holders.
  • Graduate visa holders.
  • Student visa holders.
  • Individuals with Settled Status.
  • Individuals with Pre-Settled Status.
  • Individuals granted permission under the Ukraine Schemes.
  • Individuals with other forms of digital immigration status.
  1. Sponsored Workers and Student Visa Holders

Where a worker holds immigration permission subject to sponsorship or study restrictions, QPS must undertake additional compliance checks to ensure any proposed engagement is lawful.

Sponsorship Visas

Workers sponsored under a Skilled Worker visa, Health and Care Worker visa, or any other sponsored immigration route may only undertake supplementary employment where permitted under Home Office rules.

In addition to the standard Right to Work checks outlined within this policy, QPS requires written confirmation from the sponsoring employer confirming:

  • The worker remains actively employed by the sponsor.
  • The sponsorship remains valid and active.
  • The worker’s normal contracted working hours and working pattern.
  • The worker continues to undertake the role for which sponsorship was granted.

The confirmation must be provided on company letterhead or via a verifiable company email address.

QPS will assess whether the proposed engagement complies with the supplementary work provisions applicable at the time of engagement.

No worker holding sponsored immigration status will be permitted to commence work until the required sponsor confirmation has been received and reviewed by the Compliance Department.

Student Visas

Workers holding a Student visa may be subject to restrictions on the number of hours they can work and the type of work they can undertake.

In addition to the standard Right to Work checks, QPS requires:

  • A valid Share Code and successful Home Office verification.
  • Evidence of current student status.
  • Confirmation of the worker’s academic term dates, either through:
    • A university or college enrolment letter;
    • An official academic timetable;
    • An official term date schedule; or
    • Other documentation issued by the educational institution confirming study periods.

Where work restrictions apply during term time, QPS will monitor working hours to ensure compliance with immigration requirements.

Updated evidence may be requested at the start of each academic year or whenever study arrangements change.

Failure to Provide Evidence

Where a worker is unable or unwilling to provide the documentation required under this section, QPS will not permit the worker to commence or continue an engagement.

No worker will be employed, engaged, paid or permitted to undertake any assignment until all required Right to Work, sponsorship, student status and immigration compliance checks have been completed to the satisfaction of QPS.

 

  1. Employer Checking Service (ECS)

Where an individual cannot provide a valid Share Code but claims to have an outstanding immigration application, appeal or administrative review, QPS may utilise the Home Office Employer Checking Service (ECS).

Examples include individuals who:

  • Have an outstanding visa extension application.
  • Have submitted an application for Settlement or Indefinite Leave to Remain which is awaiting decision.
  • Have an outstanding administrative review.
  • Have an outstanding immigration appeal.
  • Have other circumstances where the Home Office has confirmed that online verification is unavailable.

To submit an ECS request, the worker must provide:

  • A copy of their passport or travel document.
  • Any correspondence or supporting documentation received from the Home Office.
  • Any application reference numbers or case reference numbers available.

QPS will submit an ECS request and obtain a Positive Verification Notice (PVN) before permitting work to commence or continue.

Where a Positive Verification Notice is received, QPS will retain the notice in accordance with Home Office requirements.

 

  1. Ongoing Monitoring and Repeat Checks

QPS will monitor all time-limited Right to Work permissions.

The expiry date of any visa, immigration permission or Positive Verification Notice will be recorded within QPS systems.

QPS will:

  • Review upcoming expiries on a regular basis.
  • Contact workers and any third parties (such as recruitment agencies and end hirers) during the month preceding the expiry date.
  • Request updated immigration evidence, typically in the form of a new Share Code.
  • Conduct a fresh RTW verification before the existing permission expires.

Where satisfactory evidence is not provided before expiry, QPS reserves the right to suspend work and payment processing until compliant documentation has been received and verified.

 

  1. Record Retention

QPS will retain evidence of RTW checks for the duration of the engagement and for a minimum of two years following the end of the engagement.

Records may include:

  • TrustID verification reports.
  • Passport copies.
  • Birth certificates.
  • National Insurance evidence.
  • Driving licences.
  • Selfie photographs.
  • Home Office online check results.
  • Share Code verification results.
  • Employer Checking Service responses.
  • Positive Verification Notices.

Records will be stored securely and processed in accordance with UK GDPR and the Data Protection Act 2018.

 

  1. Non-Compliance

No individual may commence or continue work where QPS has not obtained satisfactory evidence of their Right to Work.

Any suspected fraudulent documentation, false representations or discrepancies identified during the verification process will be escalated to the Compliance Department for investigation.

QPS reserves the right to refuse engagement or terminate an engagement where legal Right to Work requirements cannot be satisfied.

 

  1. Responsibility

Overall responsibility for compliance with this policy rests with the Compliance Department.

All staff involved in onboarding, recruitment, worker engagement and payroll administration must ensure that RTW checks are completed in accordance with this policy before any worker is permitted to undertake work.

Sexual harassment policy

  1. Introduction

1.1

QPS is committed to providing a working environment where all individuals are treated with dignity, respect and professionalism.

1.2

QPS has a zero-tolerance approach to sexual harassment and is committed to taking all reasonable steps to prevent sexual harassment within its business operations and labour supply chains.

1.3

All individuals engaged by QPS have the right to work in an environment free from:

  • sexual harassment
  • bullying
  • intimidation
  • victimisation
  • offensive or degrading behaviour

1.4

This policy applies to:

  • PAYE employees
  • Umbrella PAYE workers
  • Outsourced PAYE workers
  • agency workers engaged through QPS
  • applicants, contractors and temporary workers
  • individuals working at client sites or attending work-related events

1.5

QPS expects all employees, workers, agencies, clients, suppliers and third parties engaged within the labour supply chain to uphold the standards outlined within this policy.

1.6

This policy does not form part of any contract of employment and may be amended by QPS from time to time.

 

  1. Purpose

2.1

The purpose of this policy is to:

  • prevent sexual harassment within the workplace and labour supply chain
  • provide clear reporting procedures
  • ensure concerns are handled seriously and confidentially
  • protect individuals from victimisation or retaliation
  • ensure compliance with the Equality Act 2010 and the Worker Protection (Amendment of Equality Act 2010) Act 2023

2.2

QPS is committed to taking proactive and reasonable steps to identify and prevent risks relating to sexual harassment.

2.3

Any form of sexual harassment will be treated as serious misconduct and may result in disciplinary action, termination of assignment or termination of engagement.

 

  1. What is harassment?

3.1

Harassment is unwanted conduct related to a protected characteristic which has the purpose or effect of:

  • violating an individual’s dignity; or
  • creating an intimidating, hostile, degrading, humiliating or offensive environment.

3.2

Harassment can occur:

  • verbally
  • physically
  • visually
  • electronically
  • in person
  • remotely
  • through social media, messaging platforms or electronic communications

3.3

Harassment may occur as a one-off incident or as repeated behaviour.

 

  1. What is sexual harassment?

4.1

Sexual harassment is unwanted behaviour of a sexual nature that has the purpose or effect of:

  • violating an individual’s dignity; or
  • creating an intimidating, hostile, degrading, humiliating or offensive environment.

4.2

Sexual harassment may occur regardless of:

  • gender
  • seniority
  • employment status
  • assignment type
  • working location

4.3

Examples of sexual harassment may include:

  • unwanted sexual comments or jokes
  • inappropriate remarks about appearance
  • unwanted touching, hugging, kissing or physical contact
  • sexual gestures or suggestive behaviour
  • intrusive questions of a sexual nature
  • requests for sexual favours
  • sexual advances
  • sharing sexually explicit material
  • offensive emails, messages or social media content
  • displaying sexually offensive images or materials
  • intimidation or threats linked to sexual conduct
  • victimisation following rejection of sexual advances

4.4

Behaviour may still constitute harassment even if:

  • it was not intended to offend
  • it was described as “banter” or a joke
  • the conduct occurred outside normal working hours
  • the conduct took place at a client site, social event or online

 

  1. Reporting concerns

5.1

Any individual who believes they have experienced or witnessed sexual harassment should report the matter as soon as reasonably practicable.

5.2

Concerns may be raised with:

  • a QPS manager
  • HR
  • payroll or compliance teams
  • a recruitment contact
  • the designated reporting contact under this policy

5.3

Reports may be made verbally or in writing.

5.4

Where possible, reports should include:

  • details of the incident
  • dates and times
  • names of individuals involved
  • names of any witnesses
  • supporting evidence where available

5.5

QPS recognises that reporting concerns of this nature can be difficult and all concerns will be treated seriously, sensitively and confidentially wherever reasonably practicable.

5.6

Individuals raising concerns in good faith will be protected from retaliation or victimisation.

5.7

Retaliation against any individual who raises or participates in a complaint under this policy will be treated as serious misconduct.

 

  1. Investigation process

6.1

QPS will assess all complaints promptly and determine the appropriate course of action.

6.2

Investigations may be carried out by:

  • QPS management
  • HR
  • compliance personnel
  • an independent investigator
  • the client or hirer where appropriate

6.3

Investigations may involve:

  • meetings with relevant individuals
  • witness statements
  • review of communications or evidence
  • liaison with recruitment agencies or end clients

6.4

Where appropriate, temporary measures may be implemented during the investigation process to protect affected individuals.

6.5

If sexual harassment is found to have occurred, QPS may take appropriate action including:

  • disciplinary action
  • removal from assignment
  • termination of employment or engagement
  • escalation to clients or regulators
  • reporting to law enforcement authorities where appropriate

6.6

QPS reserves the right to refuse to work with any client, supplier or third party where concerns relating to harassment, victimisation or unsafe working practices are identified.

 

  1. Responsibilities

7.1

All individuals engaged by QPS are responsible for:

  • treating others with dignity and respect
  • complying with this policy
  • helping to create a safe and inclusive working environment
  • reporting inappropriate behaviour where observed

7.2

Managers and individuals responsible for investigations must:

  • handle complaints appropriately and confidentially
  • take concerns seriously
  • avoid victimisation or retaliation
  • ensure concerns are escalated appropriately where necessary

7.3

QPS will provide appropriate training, guidance and information relating to sexual harassment prevention and reporting.

7.4

QPS may carry out due diligence checks on clients, agencies and labour supply chain partners to assess whether appropriate measures are in place to prevent harassment and protect workers.

 

  1. Monitoring and review

8.1

QPS will monitor the effectiveness of this policy and review it periodically to ensure compliance with applicable legislation and regulatory expectations.

8.2

QPS is committed to taking reasonable and proactive steps to prevent sexual harassment within the workplace and labour supply chain.

 

  1. Reporting contact

9.1

Concerns relating to sexual harassment may be reported confidentially to:

Daniel Newham
Compliance Manager
[email protected]

9.2

Where appropriate, concerns may also be escalated directly to senior management.

9.3

QPS will not tolerate victimisation, retaliation or detrimental treatment against any individual who raises a genuine concern in good faith.

 

Use of this website is governed by this website policy and you agree to be bound by them each time you access the website.

The material on this website is provided purely for your information and you should seek further guidance and make independent inquiries before relying on it. The Company may make alterations to the website at any time. You will be deemed to accept such alterations when you next use the website following any such alteration.

Any employment placement will be subject to The Company’s current standard employment terms and conditions.

The information on this website is updated from time to time. Whilst The Company has made every effort to ensure the accuracy and completeness of information on this website, The Company makes no representations or warranties whatsoever, express or implied, as to the quality, accuracy or completeness of such information.

The Company may without notice modify, suspend or discontinue the website or any part of it at any time without any liability to you or any third party.

To the full extent permitted by law, The Company accepts no liability in contract, tort or otherwise (including liability for negligence), for loss or damage of any kind including without limitation, direct or indirect loss or damage, loss of business, revenue or profits, corruption or destruction of data, or any other consequential loss or damage arising out of your use or inability to use the website (or other site linked to the website) or in connection with any computer virus or system failure and The Company excludes any such liability even if The Company is expressly advised of the possibility of such damage or loss.

You will indemnify The Company against all costs, losses, expenses or other liabilities incurred by The Company arising from the use of the website by you.

Lawful Use

You will use the website for lawful purposes only.

Links

You should note that The Company provides links to web sites maintained by others. The Company accepts no responsibility or liability for the accuracy or legality of any content contained in such websites. The fact that you may use one of these links to access other websites is not an endorsement by The Company of any content contained in those websites. Neither you nor any third party may link another site to The Company’s website without The Company’s prior written consent.

Copyright

Unless otherwise stated, the copyright and similar rights in this web site and in all the material contained on this website belong to The Company. You are only permitted to copy or print extracts of the material for your own personal use. You may not use any of this material for commercial or public purposes.

Without The Company’s written permission, you may not (whether directly or indirectly including through the use of any programme) create a database in an electronic or other form by downloading and storing all or any part of the pages from this website. Without the permission of The Company, no part of this website may be reproduced, transmitted to or stored on any other website, disseminated in any electronic or non-electronic form, or included in any public or private electronic retrieval system.

Changes to these Terms and Conditions

The Company may add to or change this policy from time to time. You are deemed to have accepted changed or additional policy statements when you access the website following any such change or addition.

The Accuracy of your Registration Information

You are responsible for ensuring that any information you provide to The Company, including your CV, is accurate, complete and your own. If The Company has any reason to believe that any information you have supplied is false, inaccurate or not your own, we may remove your ability to log-in to the site and may prohibit you from using this site. The Company is entitled, forthwith and without notice, to remove from the website any such information found to be false, inaccurate, incomplete or not your own.

Your Username and Password

You are responsible for all use of this site made using your user name and password, whether or not such use is made by you or by someone else using your user name and password. You are responsible for protecting and securing your user name and password from unauthorised use. Your user name and password must not be disclosed to another person. If you believe there has been a breach of security of your user name or password, such as theft or your username or password becoming known to someone else or unauthorised use, you must notify The Company.

Information that you post on the website

The Company reserves the right, at your cost, at any time to remove any material from the site which it believes to be salacious, defamatory or offensive or which The Company believes may be in breach of a third party’s rights, such as a third party’s intellectual property or confidentiality rights. You agree to indemnify The Company on a full and continuing basis against any loss or damage suffered or costs (including legal costs) incurred by The Company in defending any action brought against The Company as a result of any information you have posted on the website.

Governing Law and Applicable Legislation

This website policy is governed by English law and you agree that the English courts shall have exclusive jurisdiction to determine any matter or dispute arising out of or in connection with use of this website and this policy.

It is not intended that a third party should have the right to enforce any provision of this policy pursuant to the Contracts (Rights of Third Parties) Act 1999 and furthermore The Company may, and without the consent of a third party to whom the right of enforcement of any of the terms has been expressly provided vary and amend this policy.

Use of this website may not be allowed in countries outside the United Kingdom where such use may be contrary to local law or regulation. If you access information on this website it is your sole responsibility to ensure compliance with any applicable laws or regulations in any other country. Any use of this website outside the United Kingdom is your responsibility and we accept no liability whatsoever in connection with such use.

The Company has the right at any time to terminate or suspend access to, or use of, the website where The Company reasonably believes you have infringed this policy.

Bluestones Group is Registered in England, with company number 07807506. Operating Under The Employment Agencies Act 1973.

 

QPS Group worker disciplinary policy and procedure

 1. Introduction

1.1 Purpose

This policy applies to all workers employed by Quest Pay Solutions NE Limited trading as QPS Group (“QPS”) and engaged on temporary assignments with clients of QPS.

The purpose of this policy is to establish the standards of conduct expected of all workers and to provide a fair and consistent process for addressing concerns relating to conduct, behaviour or breaches of company or client rules.

 

1.2 Scope

Workers are expected to comply with:

  • Their contract of employment;
  • This policy;
  • All lawful and reasonable instructions issued by QPS;
  • Any workplace rules, procedures and policies implemented by the client to whom they are assigned.

Failure to meet these standards may result in disciplinary action.

 

1.3 Status of this policy

This policy does not form part of any contract of employment and may be amended by QPS from time to time.

 2. Standards of conduct

2.1 General expectations

While engaged on assignment, workers are expected to:

  • Attend work as agreed and be punctual;
  • Perform their duties with reasonable care, skill and diligence;
  • Behave professionally and respectfully at all times;
  • Follow all client site rules and procedures;
  • Follow all health and safety requirements;
  • Protect confidential information belonging to QPS, clients, workers and third parties;
  • Submit accurate timesheets, expenses and supporting information;
  • Maintain all qualifications, licences and certifications required for their role;
  • Maintain a valid right to work in the United Kingdom;
  • Act in a manner that protects the reputation of QPS and its clients.

 

2.2 Assignment conduct

Workers are assigned to client workplaces and are expected to comply with all reasonable workplace rules and instructions issued by the client.

Where concerns are raised by a client regarding a worker’s conduct, attendance, behaviour or compliance with site rules, QPS reserves the right to investigate the matter under this policy.

Removal from an assignment by a client will not automatically result in disciplinary action. However, the circumstances surrounding the removal may be investigated and may result in disciplinary proceedings where appropriate.

3. Misconduct

The following are examples of conduct that may be treated as misconduct:

  • Repeated lateness;
  • Failure to notify absence in accordance with company procedures;
  • Unauthorised absence from work;
  • Failure to follow reasonable instructions;
  • Failure to comply with client workplace procedures;
  • Failure to wear required personal protective equipment;
  • Inappropriate use of mobile phones or electronic devices whilst working;
  • Failure to submit timesheets or expenses correctly;
  • Minor breaches of health and safety requirements;
  • Inappropriate language or behaviour;
  • Negligence in carrying out duties;
  • Minor breaches of confidentiality;
  • Time wasting during working hours;
  • Inappropriate social media activity relating to QPS, clients or colleagues.

This list is intended as guidance only and is not exhaustive.

4. Gross misconduct

Gross misconduct is conduct so serious that it fundamentally breaches the employment relationship and may result in summary dismissal without notice.

Examples of gross misconduct include:

  • Theft or attempted theft;
  • Fraud or dishonesty;
  • Deliberate falsification of timesheets, expenses or other records;
  • Deliberate falsification of qualifications, licences or right to work documentation;
  • Physical violence, threats of violence or aggressive behaviour;
  • Bullying, harassment, discrimination or victimisation;
  • Serious breach of health and safety requirements;
  • Working under the influence of alcohol or illegal drugs;
  • Possession, use or supply of illegal drugs;
  • Deliberate damage to client, company or third-party property;
  • Serious insubordination or refusal to follow lawful instructions;
  • Serious breach of confidentiality;
  • Deliberate misuse of client or company systems;
  • Unauthorised disclosure of confidential information;
  • Conduct likely to bring QPS or its clients into serious disrepute;
  • Criminal conduct that affects suitability for continued employment or assignment;
  • Serious breach of client site rules resulting in removal from site;
  • Deliberate failure to disclose information affecting the right to work or ability to undertake an assignment.

This list is intended as guidance only and is not exhaustive.

5. Informal action

Where appropriate, minor concerns may be addressed informally through discussion with the worker.

The purpose of informal action is to clarify expectations and encourage improvement without commencing formal disciplinary proceedings.

QPS reserves the right to move directly to the formal disciplinary process where the seriousness of the matter warrants such action.

6. Investigation

Before any disciplinary action is taken, QPS will normally carry out an investigation to establish the relevant facts.

The investigation may include:

  • Reviewing relevant documents and records;
  • Obtaining information from clients;
  • Interviewing the worker concerned;
  • Interviewing witnesses.

Workers are expected to cooperate fully with any investigation.

An investigation does not imply guilt and no disciplinary decision will be made until the investigation has concluded and the worker has had an opportunity to respond.

7. Suspension

In certain circumstances, QPS may suspend a worker whilst an investigation is carried out.

Suspension is not a disciplinary sanction and does not imply any finding of wrongdoing.

Any suspension will be reviewed regularly and kept as short as reasonably possible.

 8. Disciplinary hearing

Where there is a case to answer, the worker will be invited to attend a disciplinary hearing.

The worker will be informed of:

  • The allegations;
  • The evidence supporting the allegations;
  • The possible outcomes.

Workers may be accompanied by a fellow worker or accredited trade union representative at any formal disciplinary hearing.

Following the hearing, QPS will consider all available information before reaching a decision.

9. Disciplinary outcomes

Depending on the circumstances, QPS may take one of the following actions: 

Stage 1 – First written warning

A first written warning will normally be issued where misconduct has been established and there are no active warnings on file. 

Stage 2 – Final written warning

A final written warning may be issued where:

  • Further misconduct occurs during an active warning period; or
  • The misconduct is sufficiently serious to warrant a final warning.

 

Stage 3 – Dismissal

Dismissal may occur where:

  • Further misconduct occurs during an active final written warning; or
  • Gross misconduct has been established.

Where gross misconduct is established, dismissal may be without notice or payment in lieu of notice.

10. Duration of warnings

A first written warning will normally remain active for six months.

A final written warning will normally remain active for twelve months.

Following expiry, warnings will remain on file for record-keeping purposes but will not normally be relied upon in future disciplinary decisions.

11. Appeals

Workers have the right to appeal any formal disciplinary sanction.

Appeals must be submitted in writing within five working days of receiving the disciplinary outcome.

The appeal will be heard by a manager who was not involved in the original decision wherever reasonably practicable.

The outcome of the appeal will be confirmed in writing and will be final.

12. Related policies

This policy should be read alongside:

  • Health and Safety Policy;
  • Equal Opportunities Policy;
  • Anti-Harassment and Bullying Policy;
  • Data Protection Policy;
  • Right to Work Policy;
  • Whistleblowing Policy;
  • Drug and Alcohol Policy.

QPS Group is committed to ensuring that all disciplinary matters are handled fairly, consistently and in accordance with the principles of natural justice and the ACAS Code of Practice on Disciplinary and Grievance Procedures.

Whistleblowing policy

  1. Introduction

1.1

QPS is committed to conducting its business with honesty, integrity and transparency. We expect all employees, workers and representatives engaged by QPS to maintain high standards of professional and ethical conduct.

1.2

QPS operates within regulated labour supply chains and is committed to maintaining the highest standards of compliance, transparency and ethical conduct across all payroll, employment and recruitment activities.

1.3

QPS recognises that concerns relating to wrongdoing, unlawful conduct or unsafe practices may arise from time to time. This policy provides a framework for individuals to raise genuine concerns in confidence and without fear of retaliation.

1.4

The aims of this policy are to:

  • encourage individuals to report concerns as soon as possible
  • ensure concerns are investigated appropriately
  • promote a culture of openness and accountability
  • protect individuals who raise genuine concerns in good faith
  • ensure compliance with legal and regulatory obligations

1.5

This policy applies to:

  • PAYE employees
  • Umbrella PAYE workers
  • Outsourced PAYE workers
  • agency workers engaged through QPS
  • contractors, consultants and temporary staff working on behalf of QPS

1.6

This policy may also be used by self-employed contractors, suppliers or third parties who wish to report concerns relating to QPS operations, compliance or conduct.

1.7

This policy does not form part of any contract of employment and may be updated by QPS at any time.

 

  1. What is whistleblowing?

2.1

Whistleblowing is the reporting of suspected wrongdoing, unlawful conduct, risks or dangers affecting QPS, its workers, clients or the wider public interest.

2.2

Examples of whistleblowing concerns may include:

  • criminal activity
  • fraud or financial misconduct
  • facilitation of tax evasion
  • payroll fraud or payroll non-compliance
  • false self-employment arrangements
  • mini-umbrella arrangements
  • breaches of HMRC legislation or regulatory obligations
  • modern slavery concerns
  • worker exploitation
  • unlawful deductions from pay
  • withholding holiday pay
  • bribery or corruption
  • health and safety risks
  • safeguarding concerns
  • discrimination, bullying or harassment
  • data protection breaches
  • timesheet manipulation
  • unethical conduct
  • environmental damage
  • conduct likely to damage the reputation of QPS or its clients
  • deliberate concealment of wrongdoing

2.3

This policy should not normally be used for personal employment grievances or assignment disputes. Such concerns should usually be raised under the relevant grievance or complaints procedure unless there is a wider public interest concern.

2.4

Individuals are encouraged to raise concerns even where they are uncertain whether wrongdoing has occurred. Concerns raised in good faith will always be taken seriously.

2.5

Individuals raising concerns in good faith will be protected regardless of whether the concern is ultimately substantiated, provided the disclosure was not knowingly false or malicious.

 

  1. Raising a concern

3.1

Concerns should be raised as soon as reasonably possible.

3.2

Where appropriate, concerns may initially be raised with:

  • a QPS manager
  • HR
  • payroll or compliance teams
  • a senior member of management

3.3

Where an individual does not feel comfortable raising concerns through normal operational channels, concerns may be escalated directly to the designated whistleblowing contact.

3.4

Concerns may be raised verbally or in writing. Written disclosures should include:

  • the nature of the concern
  • relevant dates and details
  • names of individuals involved where known
  • any supporting evidence available

3.5

QPS may arrange a meeting to discuss the concern further and obtain additional information where necessary.

3.6

Individuals raising concerns may request to be accompanied at formal meetings by a work colleague or trade union representative where appropriate.

3.7

All whistleblowing concerns received will be reviewed appropriately and handled as confidentially as reasonably practicable.

 

  1. Confidentiality

4.1

QPS encourages individuals to raise concerns openly wherever possible.

4.2

However, where confidentiality is requested, QPS will make every reasonable effort to protect the identity of the individual raising the concern.

4.3

In certain circumstances, it may be necessary to disclose information as part of an investigation or legal obligation. Where possible, this will be discussed in advance with the individual concerned.

4.4

Anonymous disclosures may be considered; however, investigations can be more difficult where further clarification or evidence cannot be obtained.

4.5

Information disclosed under this policy will be handled sensitively and in accordance with applicable data protection legislation wherever reasonably practicable.

 

  1. External disclosures

5.1

QPS encourages concerns to be raised internally in the first instance wherever appropriate.

5.2

However, individuals may also have the right to report concerns externally to appropriate regulatory or enforcement bodies where permitted by law.

5.3

This may include concerns relating to:

  • HMRC compliance
  • tax evasion facilitation
  • worker exploitation
  • health and safety
  • modern slavery
  • financial misconduct
  • regulatory breaches

5.4

QPS reserves the right to cooperate fully with regulatory bodies, law enforcement agencies, HMRC, the Fair Work Agency and other relevant authorities where concerns involve potential legal or regulatory breaches.

5.5

QPS strongly discourages disclosure of confidential business information to the media or social media platforms without first seeking appropriate advice.

5.6

Nothing within this policy prevents any individual from making a protected disclosure under applicable whistleblowing legislation.

 

  1. Investigation and outcome

6.1

QPS will carry out an initial assessment of all whistleblowing concerns raised.

6.2

Depending on the nature of the concern, QPS may:

  • carry out an internal investigation
  • appoint an independent investigator
  • involve external advisors or regulators
  • refer matters to law enforcement or relevant authorities

6.3

Investigations may involve:

  • reviewing payroll and financial records
  • reviewing communications or compliance documents
  • interviewing relevant individuals
  • obtaining witness statements
  • reviewing assignment or contractual arrangements

6.4

QPS will aim to keep the individual informed regarding the progress of the investigation where appropriate and reasonably practicable.

6.5

Due to confidentiality obligations, QPS may not always be able to disclose full details of any investigation outcome or disciplinary action taken.

6.6

Individuals must treat all information relating to investigations confidentially.

6.7

Where a concern is found to have been raised maliciously, dishonestly or for personal gain, disciplinary or other appropriate action may be taken.

 

  1. Protection for whistleblowers

7.1

QPS is committed to ensuring that individuals who raise genuine concerns in good faith do not suffer retaliation or detrimental treatment.

7.2

Detrimental treatment may include:

  • dismissal
  • disciplinary action
  • threats or intimidation
  • loss of work opportunities
  • discrimination
  • unfavourable treatment connected to the disclosure

7.3

Retaliation against any individual who raises a genuine concern in good faith is strictly prohibited.

7.4

Any retaliation, victimisation, intimidation or detrimental treatment will be treated as a serious disciplinary matter and may result in dismissal or termination of engagement.

7.5

Individuals who believe they have suffered detrimental treatment for raising a concern should report this immediately to HR or senior management.

 

  1. Responsibility for this policy

8.1

QPS management has overall responsibility for ensuring this policy is implemented effectively and reviewed regularly.

8.2

Managers and compliance personnel responsible for handling concerns will receive appropriate guidance and support where required.

8.3

All individuals engaged by QPS are responsible for supporting a culture of openness, accountability and ethical conduct.

8.4

This policy will be reviewed periodically to reflect legal, regulatory and operational developments within the labour supply chain and employment sectors.

 

  1. Whistleblowing contact

9.1

Whistleblowing concerns may be raised confidentially with:

Daniel Newham
Compliance Manager
[email protected]

9.2

Where appropriate, concerns may also be escalated directly to senior management where the individual does not feel comfortable reporting concerns through normal operational channels.

9.3

QPS will not tolerate retaliation, victimisation or detrimental treatment against any individual who raises a genuine concern in good faith.

Gender pay gap report

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