Corporate Responsibility

The Hemming Group recognises the benefits of a diverse workforce and is committed to providing a working environment that is free from discrimination.

HGL will seek to promote the principles of equality and diversity in all its dealings with employees, job applicants, clients, customers, suppliers, contractors, recruitment agencies and the public. 

Anti-Bribery and Corruption

It is the Company’s policy to conduct all business in an honest and ethical manner. It takes a zero-tolerance approach to bribery and corruption, and is committed to acting professionally, fairly and with integrity in all business dealings and relationships, and to implementing and enforcing effective systems to counter bribery.

Bribery and corruption are punishable for individuals by up to 10 years' imprisonment, and if the Company were found to have taken part in corruption it could face an unlimited fine, and face damage to our reputation and continued work. We therefore take our legal responsibilities very seriously.

In this policy, “third party” means any individual or organisation you may come into contact with during the course of your work, and includes actual and potential clients, customers, suppliers, distributors, business contacts, colleagues, media. These rules apply to all individuals (whether permanent, fixed-term or temporary), or any other person associated with the Company. Anyone found to be in breach of these rules will be subject to disciplinary action in accordance with the Disciplinary Policy, up to and including summary dismissal.

If you are ever offered a bribe or inducement, you must report it immediately to your Line Manageror Director. Similarly, if you ever become aware that any employee or other colleague has offered anyone else a bribe, or become involved in any form of corrupt behaviour, you must report it immediately. Failing to make such a report may result in disciplinary action being taken against you, up to and including dismissal.

What is Bribery?

A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. Examples of this could be as follows:

  • Offering a bribe: You offer some tickets to a major sporting event, but only if they agree to do business with us at strongly discounted rates. This would be an offence because you are making the offer to gain a commercial and contractual advantage. It may also be an offence for the potential supplier to accept your offer.
  •  Receiving a bribe: A supplier gives your nephew a job, but makes it clear that in return they expect you to use your influence in the Company to ensure we continue to do business with them. It is an offence for a supplier to make such an offer. It would be an offence for you to accept the offer as you would be doing so to gain a personal advantage.
  •  Bribing a foreign official: You arrange for the Company to pay an additional payment to a foreign official to speed up an administrative process [such as clearing some supplies we need through customs]. The offence of bribing a foreign public official has been committed as soon as the offer is made. This is because it is made to gain a business advantage for us. We may also be found to have committed an offence.

Gifts, gratuities and hospitality

These rules do not prohibit normal and appropriate hospitality (given and received) to or from third parties. Common sense should always prevail, or if you have any doubt over what is acceptable, always check with your Line Manager or Director before giving or receiving anything. The receipt of gifts is not prohibited, if the following requirements are met:

  • A gift is not given or received with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits
  • it complies with local law
  • it is given in the Company’s name, not in your name
  • it does not include cash or a cash equivalent (such as gift certificates or vouchers
  • it is appropriate in the circumstances. For example, it is customary for small gifts to be given at Christmas time
  • taking into account the reason for the gift, it is of an appropriate type and value and given at 
    an appropriate time
  • it is given openly, not secretly

The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered. 

However, for the avoidance of doubt, it is NOT acceptable to:

  • give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given
  • give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to "facilitate" or expedite a routine procedure
  • accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business or commercial advantage for them
  • accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business or commercial advantage will be provided by us in return
  • threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or
  • engage in any activity that might lead to a breach of this policy.

In order to ensure that any gifts, gratuities or other hospitality enjoyed by any employee or representative of the Company is beyond any suspicion, we hold a register of all such activities. Please ensure that you declare to your Line Manager or Director any hospitality you are party to, any gifts which are offered and/or accepted by you, or any donations made to the Company through you. That way we will have a complete record, and can ensure appropriate internal controls on such matters.

Equal Opportunities and Diversity Policy

The Hemming Group recognises the benefits of a diverse workforce and is committed to providing a working environment that is free from discrimination.

HGL will seek to promote the principles of equality and diversity in all its dealings with employees, job applicants, clients, customers, suppliers, contractors, recruitment agencies and the public. 

All employees and those who act on the Company's behalf are required to adhere to this policy when undertaking their duties or when representing the Company in any other guise.

Unlawful discrimination

Unlawful discrimination of any kind in the working environment will not be tolerated and the Company will take all necessary action to prevent its occurrence. Specifically, The Hemming Group aims to ensure that no employee or job applicant is subject to unlawful discrimination, either directly or indirectly, on the grounds of gender, gender reassignment, race (including colour, nationality, caste and ethnic origin), disability, sexual orientation, marital status, part-time status, pregnancy or maternity, age, religion or belief, political belief or affiliation or trade union membership or any other protected characteristic.

This commitment applies to all aspects of employment, including: 

  • recruitment and selection, including advertisements, job descriptions, interview and 
    selection procedures
  • training
  • promotion and career-development opportunities
  • terms and conditions of employment, and access to employment-related benefits and 
    facilities
  • grievance handling and the application of disciplinary procedures
  • selection for redundancy

Equal opportunities practice is developing constantly as social attitudes and legislation change. The Company will review all policies and implement necessary changes where these could improve equality of opportunity.

Career development

While positive measures may be taken to encourage under-represented groups to apply for employment opportunities, recruitment or promotion to all jobs will be based solely on merit.

All employees will have equal access to training and other career-development opportunities appropriate to their experience and abilities.

However, the Company will take appropriate positive action measures (as permitted by equal opportunities legislation) to provide specialist training and support for groups that are under-represented in the workforce and encourage them to take up training and career-development opportunities.

Complaints of discrimination

The Company will treat seriously all complaints of discrimination made by employees, clients, customers, suppliers, contractors or other third parties and will take action where appropriate. If you believe that you have been discriminated against, you are encouraged to raise the matter as soon as possible with your Line Manager, Sector Head or HR using the Company's Grievance Procedure.

Allegations regarding potential breaches of this policy will be treated in confidence and investigated thoroughly. If you make an allegation of discrimination, the Company is committed to ensuring that you are protected from victimisation, harassment or less favourable treatment. Any such incidents will be dealt with under the Company's Disciplinary Procedures.

Investigating accusations of unlawful discrimination

If you are accused of unlawful discrimination, the Company will investigate the matter fully. During the course of the investigation, you will be given the opportunity to respond to the allegation and provide an explanation of your actions. 

If the investigation concludes that the claim is false or malicious, the complainant may be subject to disciplinary action. If the investigation concludes that your actions amount to unlawful discrimination, you will be subject to disciplinary action, up to and including dismissal without notice for gross misconduct.

Modern Slavery

Hemming Group (the Company) has a zero-tolerance approach to modern slavery and is committed to preventing acts of slavery and human trafficking from occurring within both its business and supply chain, and imposes those high standards on its contractors, suppliers and other business partners.

This policy applies to all individuals working for the Company, including anyone providing services to the Company, such as consultants or contractors.

The Company aims to deliver first-class marketing, networking, media, and information solutions in high-value sectors. The vast majority of our businesses use a variety of third-party suppliers to provide us with standard goods and services necessary to operate. These may include logistical support services, IT, and office goods and services.
The partnerships we form with suppliers, contractors, agents, other businesses, and professionals are integral to our success. We aim to create and maintain sustainable partnerships of mutual value and trust. The Company expects the same high standards from those parties with whom we engage.

Policy Aim

This policy aims to help the Company act by the Modern Slavery Act 2015, maintain the highest possible standards of business practice, and advise individuals of the Company's "zero-tolerance" to slavery. Our Anti-Slavery Policy Statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our supply chains.

The Law

Modern slavery amounts to a violation of an individual's human rights. It encompasses slavery, forced and compulsory labour, and human trafficking, whereby individuals are deprived of their freedom and are exploited for commercial or personal gain as enacted in the Modern Slavery Act 2015 ('the Act'). The prevention, detection, and reporting of
modern slavery in any part of its business or supply chains is the responsibility of all those working for the Company or under its control.

Policy Statement

The Hemming Group takes its responsibilities to combat modern slavery seriously, as demonstrated by the following measures:

  • All those working for the company or under its control are responsible for preventing, detecting, and reporting modern slavery in any part of its business or supply chains.
  • All supply chain lines are continually risk assessed and managed regarding modern slavery, and any high-risk suppliers are audited.
  •  The Company will not knowingly support or deal with any business involved in slavery or human trafficking.
  •  Our practices are regularly audited and reviewed to ensure that all employees have appropriate right-to-work documents, are paid fairly, and enjoy a competitive remuneration package.
  • The Company encourages anyone to raise any concerns about modern slavery and will support anyone who acts in good faith.
  • This Anti-slavery policy is published on our website.
  • The Company will continue to develop its commitment to combat modern slavery and will provide staff training where appropriate.
  • This policy applies to all permanent and fixed-term staff employed by the Company, as well as any contractors, consultants, or other persons acting under or on behalf of the Company.

Enforcement

Employees failing to observe this policy may be subject to disciplinary action by the Company's Disciplinary Policy. We reserve the right to terminate our relationship with a business partner who fails to comply with this policy.

Monitoring Policy

The policy will be monitored on an ongoing basis to ensure that it addresses issues effectively. The directors will regularly review the policy to ensure its continuing suitability and relevance to the company's activities.

The Company will ensure that all individuals working for the Company are advised of the policy.

Reviewing Policy

This policy will be reviewed and, if necessary, revised in the light of legislative or organisational changes. Improvements will be made by learning from experience and the use of an established annual review.

Policy Amendments

Should this policy be amended, revised, or updated, it is the responsibility of Company senior management to ensure that all relevant employees receive notice. Written notice and/or training should be considered.