Our Policies

Code of Conduct

Here you can see our Code of Conduct, which is shared with all our people to ensure they have a robust framework to follow in their decision making and activities.

Corporate Social Responsibility Policy 

OCU is committed to deliver safely and responsibly to our clients, suppliers, our employees and the communities in which we work and whilst delivering our services, we seek to support the needs of these stakeholders by ensuring that our business is conducted according to ethical, professional and legal standards. 

We will: 

• Conduct activities and relationships with integrity, in an ethical and honest manner, be accountable for its actions and adopt an approach of self-regulation. 
• Provide a quality product and a reliable service and will undertake a programme of continuous improvement. 
• Strive to improve our environmental performance through implementation and development of environmental practices to reduce the impact of our activities on the environment, protect biodiversity and where possible use materials, material suppliers, labour and resources local to its operation. 
• Provide, and strive to maintain a healthy and safe environment so that no one suffers harm during the course of our operations. 
• Encourage relationships with the local community, partners and clients for mutual benefit and by support and encourage our employees to help local community organisations and activities in our region. 
• Operate an equal opportunities policy for all present and potential future employees along with safeguards to ensure all employees are treated with respect and without sexual, physical or mental harassment. 
• In addition to offering our employees clear and fair terms of employment and providing resources to enable their continual development. 
• Encourage and work with suppliers and contractors to adopt responsible business policies and practices for mutual benefit. 

We will ensure that this Policy is pursued throughout the organisation and will give full backing to the Senior Management Team whose function it shall be to monitor and report on its implementation. 

This Policy shall be communicated to all employees and any amendments will be brought to their attention via their line management. 

Environment and Sustainability Policy

OCU is committed to meeting industry best practice in environmental and sustainability performance and to this end we maintain organisational structures, management systems, procedures and training plans to ensure, as a minimum, compliance with all relevant laws, regulations and standards. Our Environmental Management Systems are certified to ISO 14001:2015. We recognise the need to conduct and develop our business, with no or minimal impact to the environment and without compromising the needs of the future generations. 

We believe that by identifying our impacts and managing our operations with care our business can make a positive contribution to society and the Environment. We believe that good environmental and sustainability performance helps ensure good business performance and will be pursued as an integral part of fulfilling our corporate vision. 

Our vision is: 

That all our operations are healthy, safe and sustainable for our people and our planet. 

We will do this by: 

• Understanding our stakeholders’ expectations and requirements regarding the environment and sustainability. 
• Ensuring our employees and delivery partners have the competence to continually improve our environmental and sustainability performance 
• Assessing and reducing the negative environmental impacts of our work and maximising opportunities to have a positive impact 

We will seek continuous improvement by implementing the following principles: 

• Develop and promote policies and procedures that minimise the environmental impacts that our activities have upon the environment, prevent pollution and deal with emergencies efficiently and effectively. 
• Make efficient use of energy and natural resources and, where possible, minimise the use of raw materials and the production of waste. 
• Think carefully about the life cycle stages that can be controlled or influenced by us including raw material acquisition, design, production, transportation, use, end-of-life treatment and final disposal of our services and physical assets 
• Assess the impact of any project on the environment at the location where the work is to take place and work to reduce it 
• Communicate the social, economic and environmental aspects of our contracts by engaging with all stakeholders appropriately. 
• Continuously monitor environmental and sustainability performance by setting business targets. 
• Improve waste management practices through careful assessment of requirements. 

Our long term objectives are to: 

• Operate with net-zero greenhouse gas emissions throughout our business by 2040. 
• Reduce our impact on the quality of our air, water and soil and by protecting biodiversity. 
• Reduce consumption of natural resources by re-use, recycling and use of sustainable materials. 
• Strive to address national priorities by reducing our use of non-renewable raw materials such as fossil fuels and minerals. 
• Reduce the demand for, conserve and recycle water resources where possible and protect water suppliers from contamination. 
• Protect and enhance ecological resources and the environment. 
• Source materials responsibly and favour those with low environmental impact. 

In the short to medium term we will: 

• Collate information on our energy use from our Offices, Plant & Vehicles in order to establish our Carbon Footprint. 

All employees and those working on our behalf will be made aware of this policy. We will ensure that it is visible; displayed at all our locations and on our intranet. The board of directors gives its full support to this policy and shall ensure it is communicated, implemented, and reviewed at least once a year. This policy shall apply to all the subsidiary companies of OCU Group Limited. 

Equality and Diversity Policy

OCU recognises that discrimination and victimisation is unacceptable and that it is in the interests of the company and its employees to utilise the skills of the total workforce. It is the aim of the company to ensure that no employee or job applicant receives less favourable facilities or treatment (either directly or indirectly) in recruitment or employment on grounds of age, disability, gender/gender reassignment, marriage/civil partnership, pregnancy /maternity, race, religion or belief, sex, or sexual orientation (the protected characteristics). Our aim is that our workforce will be truly representative of all sections of society and each employee feels respected and able to give their best.

We oppose all forms of unlawful and unfair discrimination or victimisation. To that end the purpose of this policy is to provide equality and fairness for all in our employment. All employees, whether part-time, full-time or temporary, will be treated fairly and with respect. Selection for employment, promotion, training or any other benefit will be on the basis of aptitude and ability. All employees will be helped and encouraged to develop their full potential and the talents and resources of the workforce will be fully utilised to maximise the efficiency of the organisation.

Our staff will not discriminate directly or indirectly, or harass customers or clients because of age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex and sexual orientation in the provision of the Company’s goods and services. This policy and the associated arrangements shall operate in accordance with statutory requirements. In addition, full account will be taken of any guidance or Codes of Practice issued by the Equality and Human Rights Commission, any Government Departments, and any other statutory bodies.

Our Commitment 

• To create an environment in which individual differences and the contributions of all our staff are recognised and valued.
• Every employee is entitled to a working environment that promotes dignity and respect for all. No form of intimidation, bullying or harassment will be tolerated.
• Training, development and progression opportunities are available to all staff.
• To promote equality in the workplace which we believe is good management practice and makes sound business sense.
• We will review all our employment practices and procedures to ensure fairness.
• Breaches of our equality policy will be regarded as misconduct and could lead to disciplinary proceedings.
• This Policy is fully supported by the Senior Management Team.
• The Policy will be monitored and reviewed annually

Responsibilities of Management

Responsibility for ensuring the effective implementation and operation of the arrangements will rest with the CEO, Group company Managing Directors, and Senior Management Team who will ensure that they and their staff operate within this Policy and arrangements, and that all reasonable and practical steps are taken to avoid discrimination.

The Senior Management Team will ensure that:

• All their staff are aware of the Policy and the arrangements, and the reasons for the Policy;
• Grievances concerning discrimination are dealt with properly, fairly and as quickly as possible;
• Proper records are maintained.
• Human Resources/Head Office will be responsible for monitoring the operation of the Policy in respect of employees and job applicants, including periodic departmental audits.

Responsibilities of Staff

Responsibility for ensuring there is no unlawful discrimination rests with all staff and the attitudes of staff are crucial to the successful operation of fair employment practices. In particular, all members of staff should:

• Comply with the Policy and arrangements;
• Not discriminate in their day to day activities or induce others to do so;
• Not victimise, harass or intimidate other staff or groups who have, or are perceived to have one of the protected characteristics.
• Ensure no individual is discriminated against or harassed because of their association with another individual who has a protected characteristic and inform their Line Manager if they become aware of any discriminatory practice.

Third Parties

Third-party harassment occurs where a company employee is harassed, and the harassment is related to a protected characteristic, by third parties such as clients or customers. OCU will not tolerate such actions against its staff, and the employee concerned should inform their Line Manager/Supervisor at once that this has occurred. OCU will fully investigate and take all reasonable steps to ensure such harassment does not happen again.

Related Policies and Arrangements

All employment policies and arrangements have a bearing on equality of opportunity. The company policies will be reviewed regularly, and any discriminatory elements removed.

Rights of Disabled People

The company attaches particular importance to the needs of disabled people. Under the terms of this Policy, the Senior Management Team is required to:

• Make reasonable adjustment to maintain the services of an employee who becomes disabled, for example, training, provision of special equipment, reduced working hours. (NB: managers are expected
  to seek advice on the availability of advice and guidance from external agencies to maintain disabled people in employment).
• Include disabled people in training/development programmes.
• Give full and proper consideration to disabled people who apply for jobs, having regard to making reasonable adjustments for their particular aptitudes and abilities to allow them to be able to do the job.

Equality Training

A series of regular briefing sessions will be held for staff on equality issues. These will be repeated as necessary. Equality information is also included in induction programmes.

Monitoring

• The company deems it appropriate to state its intention not to discriminate and assumes that this will be translated into practice consistently across the organisation as a whole. Accordingly, a monitoring system will be introduced to measure the effectiveness of the Policy and arrangements.
• The system will involve the routine collection and analysis of information on employees by gender, marital status, ethnic origin, sexual orientation, religion/beliefs, grade and length of service in current grade. Information regarding the number of staff who declare themselves as disabled will also be maintained.
• There will also be regular assessments to measure the extent to which recruitment to first appointment, internal promotion and access to training/development opportunities affect equal opportunities for all groups.
• We will maintain information on staff who have been involved in certain key policies: Disciplinary, Grievance and Bullying and Harassment.
• Where appropriate equality impact assessments will be carried out on the results of monitoring to ascertain the effect of the company policies and our services/products may have on those who experience them.
• The information collected for monitoring purposes will be treated as confidential and it will not be used for any other purpose.
• If monitoring shows that the company, or areas within it, are not representative, or that sections of our workforce are not progressing properly within the company, then an action plan will be developed to address these issues. This will include a review of recruitment and selection procedures, company policies and practices as well as consideration of taking legal Positive Action.

Grievances/Discipline

Employees have a right to pursue a complaint concerning discrimination or victimisation via the company Grievance or Harassment Procedures. Discrimination and victimisation will be treated as disciplinary offences and they will be dealt with under the Company Disciplinary Procedure.

Review

The effectiveness of this Policy and associated arrangements will be reviewed annually under direct Supervision of the Company Managing Director.

Gender Pay Gap Report

Click here to download the statement in full.

Health and Safety Policy 

At OCU health and safety is a core value. The health, safety and wellbeing of our employees, delivery partners and those affected by our operations is our paramount concern and must never be compromised by other objectives. We are committed to proactive health, safety, and wellbeing at all levels, positively influencing all stakeholders. 

Our vision is: 

That all our operations are healthy, safe and sustainable for our people and our planet. 

We will: 

• Empower employees or those working on our behalf to challenge any un-safe acts or site conditions they witness whilst undertaking work and stop work if it is unsafe to continue. 
• Foster a culture that actively encourages open discussion and the reporting of all safety concerns, accidents, incidents, close calls, near misses and interventions. 
• Commit to consult with and provide opportunities for participation of workers, and where they exist, workers’ representatives, in matters related to Health and Safety. 
• Maintain our management systems and certification to ISO45001. 
• Comply with our legal obligations and requirements of our Health, Safety and Wellbeing management systems and other relevant requirements. 
• Provide and maintain safe vehicles, plant, equipment, and systems of work. 
• Provide and maintain safe places of work and risk-free means of entry and exit from them. 
• Provide adequate information, instruction, training, and supervision to enable persons to work safely. 
• Make a continuous effort to prevent accidents and cases of work-related ill-health. 
• Investigate all incidents to establish lessons learnt and incorporate improvements to our safety management system. 
• Establish goals and key performance indicators which will be reviewed monthly to seek improvements. 
• Make the health and safety commitment of all our delivery partners a crucial consideration in their selection. 
• Expect our delivery partners to demonstrate compliance with our standards and management systems. 
• Deliver an occupational health surveillance programme to ensure our health protection measures remain effective. 
• Develop a positive culture around mental health and provide support to our employees and delivery partners. 
• Engage openly with our clients and industry to share best practice and learn from others. 

In the short to medium term we will:

• Increase visible leadership and continue to empower people to speak up about health and safety. 
• Reinforce the responsibility of individuals to stop work when it’s unsafe to continue. 
• Monitor performance using leading and lagging indicators. 

All employees and those working on our behalf will be made aware of this Policy. We will ensure that it is visible; displayed at all our locations and on our intranet. 

The Board of Directors gives its full support to this Policy and shall ensure it is communicated, implemented, and reviewed at least once a year, and applies to all OCU Group companies. 

Information Security Policy

OCU recognises the importance of Information Security in the conduct of its business and has implemented an Information Security Management System (ISMS) which conforms to ISO 27001:2022, the international Standard for Information Security.  The ISMS ensures the continued satisfaction of relevant interested parties, through the assurance it provides, ensuring OCU Group’s continued competitive and economic performance in its business areas.

This Information Security Policy defines OCU Groups commitment to the establishment and maintenance of its ISMS, which is appropriate to its organisational purpose, and ensures the preservation of the Confidentiality, Integrity and Availability of information and information assets belonging to OCU Group.

The following objectives relative to information security have been established on behalf of OCU Group:

• The continued compliance with all relevant legal, regulatory and contractual obligations.
• The incorporation of senior representatives from all OCU Group Divisions with responsibility for the management and approval of ISMS associated functions.
• The adoption of a risk-based approach to information security and the associated risks relating to its organisational objectives.
• The development and maintenance of supporting policies relevant to the ISMS.

OCU Group top management is committed to the continual improvement of its ISMS, and conducts regular reviews of current group practices, policies and guidance, implementing any changes or improvements to ensure that appropriate security measures are applied to all its activities.

Information Security is the responsible of all employees, contractors and sub-contractors of the company.  OCU Group acknowledges that the motivation of employees is dependent upon their training and understanding of tasks they are expected to perform.  OCU Group therefore ensures that this Information Security Policy and all associated policies relevant to the ISMS is communicated, understood and acknowledged by its staff.

This Policy and associated ISMS policies is also made available to other interested parties, as applicable.

Modern Slavery Statement

This statement is made by OCU Group Limited and its subsidiaries pursuant to section 54 of Part 6 of the UK Modern Slavery Act 2015. It sets out steps which we have taken during the financial year ended 30 April 2024 to mitigate the risk of modern slavery in our business and our supply chains.

Introduction from the Chief Executive Officer

Our approach to business is captured in our new Code of Conduct which sets out the principles through which we seek to create a sustainable business for all our stakeholders, including our shareholders, clients, employees, suppliers and contractors, business partners, local communities and members of the public. We believe that sustainable growth is only possible in an environment which treats all stakeholders with respect and integrity and is fair, transparent and honest.

A key part of this is ensuring that we do not engage directly or indirectly in slavery or human trafficking, and this is a key priority for our executive management and our Board of Directors.

Modern slavery is a crime and a gross violation of fundamental human rights. It takes various forms, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere in our own business or in any of our supply chains.

We are also committed to ensuring that there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and, as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We expect our suppliers to hold their own suppliers to the same high standards.

Our Business and Organisation Structure

OCU Group Limited provides design, build, installation and maintenance services across engineering in the Energy, Utilities, and Digital Infrastructure markets. We operate throughout the UK & Ireland based from our Head Office in Manchester and through our national network of offices and operational premises.

Our Supply Chains

We have a large supply base of suppliers, the majority of which are based in the UK and are geographically aligned to projects, supporting our ethos of engaging local support. We use our suppliers to provide a variety of industry related goods and services.

Our Policy on Slavery and Human Trafficking

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

We are also committed to the principles enshrined in the International Labour Organisation Conventions and the United Nations Convention on the Rights of the Child.

The Risks of Modern Slavery in Group Operations and Supply Chains

The ‘risks of modern slavery practices’ means the potential for the Group to cause, contribute to, or be directly linked to slavery, servitude, forced labour or human trafficking within our operations or supply chains.

We maintain strict employment and engagement standards in relation to our employees and contractors and a high degree of transparency and appropriate controls over human resources and labour systems. Accordingly, we do not consider that the Group’s direct operations present a significant risk for modern slavery. We maintain confidential, anonymous and freely available reporting mechanisms set out in our Whistleblowing Policy which facilitates reporting of suspected misconduct or any improper practices. Our Code of Conduct and Supplier Code of Conduct also requires that all employees and suppliers report any suspected non-compliance with the Group’s policies and applicable laws (including modern slavery laws).

In relation to our supply chain, potential risks relate to materials, goods and services that we source through suppliers. These include possible risks of modern slavery in relation to deceptive recruiting practices, child labour, underpayment of wages, exploitation of migrant workers and bonded labour/servitude. We have assessed the residual risk as low based on the territories from which we source, historic and current supplier performance, the nature of our business relationship with our suppliers and the supporting policies and processes we have in place to help manage these risks.

Due Diligence Processes for Slavery and Human Trafficking

As part of our initiative to identify and mitigate risk, we undertake due diligence when taking on new suppliers and regularly review existing suppliers.

This includes:

• Mapping the supply chain to assess particular service or geographical risks of modern slavery and human trafficking (using guidance from the Global Slavery Index);
• Evaluating the modern slavery and human trafficking risks of each new supplier and reviewing all aspects of the supply chain on a regular basis based on the supply chain mapping exercise;
• Ensuring that all internal processes are being adhered to, for example ensuring that personnel provided by suppliers have the right to work in the UK, ensuring that limited company contractors are paid into verified bank accounts and ensuring that suppliers of personnel do not use offshore payment solutions;
• Vigilance during on-site supplier audits and inspections, and where breaches are identified, supporting a supplier to implement a corrective action plan with the aim of resolving breaches within an agreed time period, assisting to improve suppliers’ practices by sharing best in-house practice within an open forum and imposing sanctions against suppliers that fail to improve their performance in line with an action plan or seriously breach our supplier code of conduct, which can include the termination of the business relationship.

We have also continued to strengthen our processes in 2024, including having introduced a reassessment process both every 12 months and immediately when there is a change to a contract or working arrangements and deployment of an identity verification system, Veri mark which carries DBS, right to work and employment reference checks to ensure transparency across our workforce.

Our onboarding induction for both office based staff and operatives also now includes modern slavery awareness training and a reminder of the ability to raise concerns to the independent whistleblowing hotline operated by Navex EthicsPoint.

We have in place systems to:

• Identify and assess potential risk areas in our supply chains;
• Mitigate the risk of slavery and human trafficking occurring in our supply chains;
• Monitor potential risk areas in our supply chains;
• protect whistleblowers; and
• continually monitor subcontractor adherence.

Supplier Adherence to Our Values

We have zero tolerance to slavery and human trafficking. To ensure that all those in our supply chain and contractors comply with our values and ethics, we have implemented processes to:

• Clearly communicate our expectations to our supply chain in respect of sustainability, anti-corruption and bribery and ethical procurement;
• Encourage our suppliers to cascade a similar process and expectation within their own business and supply chains;
• Ensure suppliers adhere to our policies regarding supplier selection, on-boarding, risk analysis, performance measurement and continual assessment by making adherence to these policies a part of our contracts with our suppliers; and
• We have built on the central processes within the last year to introduce a central interface platform called Pay apps for subcontractor diligence that is monitored to ensure modern slavery policy adherence by subcontractors.

We seek to monitor any risk areas and encourage anyone to report any concerns regarding supplier activities.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide our employees, suppliers and subcontractors with a copy of the modern slavery policy and encourage them to report any concerns to their line manager. We have also included the policy in the Employee Handbook and cover it in our business ethics training, which is delivered to all managers, supervisors and subcontractors.

Our Effectiveness in Combating Slavery and Human Trafficking

We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

• Our aim is to ensure that 100% of new employees, workers and contractors are familiar with our modern slavery and human trafficking policy and statement and sign an acknowledgement in respect of this;
• Our aim is to ensure that 100% of new and existing large-scale suppliers provide us with a copy of their modern slavery and human trafficking statement;
• Our aim to issue our modern slavery and human trafficking policy to those suppliers who are judged to be potentially higher risk i.e. existing and new suppliers of personnel and existing and new overseas suppliers and obtain signed confirmation from each supplier that they comply with our policy on modern slavery and human trafficking.

Further Steps

Following a review of the effectiveness of the steps we have taken this year to ensure that there is no slavery or human trafficking in our supply chains, we will continue to improve our processes and encourage our staff to report any concerns they have, either to their line manager, General Counsel or using our Whistleblowing hotline.

Consultation and Approval

OCU Group is managed by a centralised senior executive team with responsibility for OCU Group’s business, including all subsidiaries. This statement was prepared by OCU Group with consultation and input from managers responsible for OCU Group’s operations and supply chains, including the commercial, finance and procurement teams and the legal, governance and compliance team.

This Statement was approved by the Board of OCU Group Limited on 27 January 2025.

Occupational Health Policy 

At OCU health and safety is a core value. The health, safety and wellbeing of our employees, delivery partners and those affected by our operations is our paramount concern and must never be compromised by other objectives. We are committed to proactive health, safety, and wellbeing at all levels, positively influencing all stakeholders. 

Our vision is: 

That all our operations are healthy, safe and sustainable for our people and our planet. The company is committed to providing an environment which promotes and maintains the wellbeing and good health (both mental and physical) of all personnel engaged in work for OCU. We recognise the importance of investing in the health and welfare of our staff by providing a physical and social environment which is conducive to teaching, learning, living, and working. In addition to meeting all legal requirements, we will take a proactive approach to workplace wellbeing by ensuring that mechanisms are in place to prevent work-related occupational health injuries and to promote good mental and physical health. We will encourage the development of a culture in which Managers take an interest in the health and wellbeing of their staff and employees themselves adopt a responsible approach to measures within their own control to keep healthy. 

We will: 

• Deliver an occupational health surveillance programme to ensure our health protection measures remain effective. 
• Provide regular wellbeing clinics across all sites, which will include the opportunity for all to attend, where advice on exercise, diet and work/life balance will be available and should assist employees to make informed choices regarding lifestyle issues. 
• Provide pre-employment self-medical screening for all new employees to ascertain whether an individual is fit to perform the job for which he/she is being considered. 
• Prospective employees who will be undertaking safety critical roles will be required to undergo a safety critical assessment. Full account will be taken of the Disability, Discrimination, and the General Data Protection Regulations. 
• Promote healthy lifestyle choices. 
• Ensure that planning and tasking decisions are taken with a consideration for the potential to cause stress and mental health issues to those involved. 
• Promote our ‘Mindset’ Behavioural Safety programme. 
• Empower individuals to develop the knowledge and understanding to make informed choices about their health, well-being, and safety, and reducing risk-taking behaviour 
• Provide both ‘with cause’ and ‘random’ drugs & alcohol testing on all our sites and in our offices. We will also provide advice and help to any Company employee who discloses a drugs or alcohol dependency. 
• Encourage our workforce to take responsibility for all aspects of their own health, which are within their own control, such as accepting and acting on advice provided in wellbeing clinics and visiting their GPs as and when required to ensure that routine tests are conducted, and their health is regularly monitored. 
• Make a continuous effort to prevent cases of work-related ill-health. 
• Establish goals and key performance indicators which will be reviewed monthly to seek improvements. 
• Engage openly with our clients and industry to share best practice and learn from others. 

In the short to medium term we will:

• Increase visible leadership and continue to empower people to speak up about mental health and wellbeing. 
• Develop a positive culture around mental health and provide support to our employees and supply chain. 

The Board of Directors gives its full support to this Policy and shall ensure it is communicated, implemented, and reviewed at least once a year. This policy shall apply to all OCU Group companies. 

Tax Strategy

This UK Tax Strategy applies to the OCU Group of companies (“the Group”) for the accounting period ending 30 April 2024.  It has been approved by the Board of Directors and is published in accordance with paragraph 16 of Schedule 19 to the Finance Act 2016.  

This document provides commentary in respect of:

1. the Group’s approach to risk management and governance arrangements in relation to UK taxation;
2. the attitude of the Group towards tax planning (so far as affecting UK taxation);
3. the level of risk in relation to UK taxation that the Group is prepared to accept; and
4. the approach of the Group towards its dealings with HMRC.

Objectives

The Group’s overriding objective is to comply with the applicable tax rules in the UK, to pay the appropriate amount of tax at the right time, and to maintain an open and honest working relationship with HMRC. 

Tax Risk Management and Governance

The Group CFO and Group Tax Manager ultimately have responsibility for the Group’s tax strategy, the supporting governance framework, and the management of tax risk.  

Tax risks are identified and assessed as part of the Group’s wider control processes for business risks.  The Group has a policy of managing tax risk by implementing appropriate controls to mitigate the risk to an acceptable level.

Appropriately qualified individuals manage the Group’s tax affairs. Where there is uncertainty about the application or interpretation of tax law, appropriate advice is sought from reputable professional firms.

Attitude to tax planning

The Group aims for certainty regarding the tax positions adopted and seeks to take advantage of available tax incentives, reliefs, and exemptions to minimise tax liabilities.  

The Group will not engage in artificial transactions, the sole purpose of which is to reduce tax.  However, the Group will consider undertaking a transaction that gives rise to tax efficiencies, providing this is aligned with the Group’s commercial objectives and complies with the associated tax legislation.  

If the Group acquires businesses, it will seek to bring its approach to tax planning and management of tax affairs in line with the Group as soon as pragmatically possible. 

Level of Risk

The Group considers itself prepared to accept a low level of risk in respect of UK taxation matters. We seek to comply with the tax laws and minimise the risk of a dispute with HMRC. Where there is ambiguity about how a transaction or course of action is taxed, we will discuss it with HMRC and take external advice where appropriate.

Relationship with HMRC

OCU Group seeks to establish and maintain a transparent, collaborative, and professional relationship with HMRC.  This is achieved by:

• Timely submission of tax returns and prompt responses to queries arising;
• Pro-actively informing HMRC on the discovery of any errors or omissions;
• Communication with HMRC around complex or evolving issues; and,
• Adopting a cooperative approach to resolving questions over tax law interpretation.

Whistleblowing Policy

Purpose

• The purpose of this Whistleblowing Policy (the “Policy”) is to establish the guidelines for reporting any actual or suspected abuse or non-compliance with any of the policies, procedures, values or business principles of OCU Group Limited and any of its direct or indirect holding companies, subsidiaries or affiliates (the “Group”), any other misconduct or improper state of affairs or circumstances in relation to the Group, or breach of any other law or regulation (“Suspected Misconduct”). This Policy should be read in conjunction with our Group Code of Conduct and related policies.
• This policy does not form part of any contract of employment or other contract to provide services, and we may amend it at any time.

Our commitment

• We conduct all our business in an honest and ethical manner. A key part of that is for all of our employees, contractors, consultants, suppliers and other counterparties to conduct their business with integrity, both in accordance with our internal policies and procedures, and within the limit and spirit of all applicable laws and regulations.
• We act with honesty, integrity, respect and accountability and we need the support of everyone to ensure we uphold these standards across the Group. In particular, everyone is responsible for speaking up if they witness or become aware of any Suspected Misconduct.
• You can trust that any disclosure will not only be treated confidentially and sensitively, but will be evaluated, and where appropriate investigated, thoroughly. We will not tolerate any kind of reprisal against someone for making a good faith disclosure of Suspected Misconduct.

Who does this policy apply to?

• The Board of OCU Group and the Executive Committee have committed themselves to this Policy and its implementation throughout the Group.
• This Policy applies to the whole Group, including all full-time, part-time, temporary, seasonal or other employees (including work experience and trainees), as well as all contractors, consultants, officers, directors, representatives, agents, suppliers (whether paid or unpaid, including employees of suppliers) and associates.
• The Group will review this Policy annually and if you have any questions regarding this Policy, you should consult with the Group General Counsel.

Who is responsible for the policy?

• The Board has overall responsibility for the effective operation of this policy but has delegated responsibility for overseeing its implementation to the Group General Counsel. Suggestions for change should be reported to the Group General Counsel.
• This Policy is reviewed routinely by the Group General Counsel and no less than on an annual basis.

What is Whistleblowing?

• Whistleblowing is the disclosure of any Suspected Misconduct. You do not have to be sure of an allegation, a reasonable suspicion is enough.
• Examples of Suspected Misconduct include:
  • behaviour that puts the health and safety of any other individual (including clients, employees, contractors or members of the public) at risk;
  • behaviour that risks contamination of the environment;
  • breach of any Group policy or procedure;
  • breach of any legal requirement – such as a law or regulation;
  • conduct that makes you feel uncomfortable or harassed in the workplace;
  • discriminatory behaviour; and
  • dishonest behaviour.
    These are just examples and not an exhaustive list.

• You can make a disclosure of Suspected Misconduct on your own behalf or on behalf of another – for example if you are aware of mistreatment of a colleague or if you have heard about, but not witnessed, breaches of policy.
• A whistleblower is anyone who makes a disclosure about Suspected Misconduct regardless of whether the disclosure is made to the confidential hotline, a line manager, director, senior manager, a member of the Legal, Governance and Compliance team, HR or a member of the Executive Committee.

How do I make a disclosure?

• The Group encourages anyone making a disclosure of Suspected Misconduct to do so in their own name. This makes it far easier for us to investigate the disclosure more effectively and to make sure that your rights and interests as a whistleblower are protected. If you are comfortable talking to a senior manager or a member of the Legal, Governance & Compliance team then that should be the first person you go to. They will be able to escalate your disclosure through the appropriate internal channels.
• If you do not feel comfortable discussing the disclosure or the Suspected Misconduct involves a senior manager, you can discuss it directly with the Group General Counsel.
• If you would rather make your complaint anonymously, please use the confidential whistleblowing service provided by Navex Global by calling 0808 196 8170 or at ocugroup.ethicspoint.com
• When making your disclosure of Suspected Misconduct it is vital that you provide us with as much information as possible to give us the opportunity to evaluate and investigate your concerns. In addition, providing us with relevant documents is particularly useful.
• Ideally, when making a disclosure, you should make it clear it is under this Policy; that will ensure that the person you are reporting to knows to follow this Policy from the outset.

How will I be protected?

• The Group adheres to all legislation that offers specific protection to whistleblowers in certain situations, for example when making disclosures about matters in the public interest. The law provides protection from dismissal (in respect of employees) and victimisation to individuals making those types of disclosures. This Policy extends that protection to employees making disclosures of any Suspected Misconduct, not just those individuals protected by law.
• Put simply, the Group will not tolerate any reprisals against anyone for making a good faith allegation of Suspected Misconduct, even if is later determined that there was, in fact, no misconduct.
• The allegation must of course be made with good faith. As much as the Group will protect those who make good faith disclosures, it will also treat seriously anyone who makes bad faith or malicious allegations against others.
• The Group is committed to supporting anyone who makes a disclosure of Suspected Misconduct throughout the process. We know it can be a stressful time and we are committed to ensuring there is support where needed. We therefore make the following commitments to everyone who makes a disclosure of Suspected Misconduct:
  • you will be treated sensitively;
  • your confidentiality will be respected and we will make every reasonable effort not to reveal your identity, if that is your preference;
  • you will be supported by senior management; and
  • you will receive reasonable updates of the investigatory process.

What will OCU do?

• If you make the disclosure of Suspected Misconduct directly, we will take as much information from you as possible.
• We will consider who in the Group organisation is best placed to deal with the allegation and any further investigation which is required in accordance with the Group’s policies and procedures in force from time to time.
• Your role in any potential investigation will depend on the specific circumstances and will vary from case to case. However, you will be told who you should contact if you have any concerns that your disclosure is not being treated properly.
• You will be given appropriate updates about the steps taken to examine the disclosure, although it may not be possible to provide you with information of every step taken. This is to respect the confidentiality of all parties concerned.
• If you make your disclosure anonymously, it will not be possible to provide you with updates or confirmation of next steps. Where a disclosure is made anonymously, the Group will not try to discover who made that disclosure.

What do I do if I receive a whistleblowing report?

• If an individual, whether in your direct management line or otherwise, approaches you to make a whistleblowing report, you must:
  • ask the individual if they wish to remain anonymous in their report, and if they do, you should encourage them to use the confidential hotline service in order to protect their identity;
  • if they do not wish to remain anonymous, you should take their report with as much detail as can be provided; and
  • after receiving the report, you must contact the Group General Counsel and ask that they log the report in the case management system.
• You should not conduct any investigation or respond to the whistleblowing report before the case is logged in the case management system and you receive advice on the appropriate conduct of any investigation from the Group General Counsel.

Questions & answers

Q: I’m not sure if my allegation is true, should I still report it?
A:  Yes! You should report any suspicion you have in good faith. You will be supported          and your disclosure will be evaluated and potentially investigated before any further steps are taken.

Q:  I have witnessed my line manager breaching our Group Code of Conduct. I know I should report it but I am worried it will affect my promotion. Can I wait a while to make a disclosure?

A: No. You should make your disclosure straight away. Obviously in this situation you will want to make your disclosure to the Group General Counsel or make the disclosure anonymously. You will not be discriminated against or prejudiced in your work by having made a disclosure.

Q: Someone has made a false allegation about me, what do I do?
A: Every disclosure is taken seriously and will be evaluated. If you are the subject of a credible disclosure, you will be given the opportunity to respond to the allegation that has been made and, if possible, provide any evidence in support of your position. However, any reprisals against someone who has made an allegation will not be tolerated and may result in disciplinary action.

Navex telephone number

You can access the confidential whistleblowing service by calling 0808 196 8170 or at ocugroup.ethicspoint.com

Work Safe Policy 

At OCU, health and safety are core values, and we acknowledge that all employees operating across multiple sectors in civil engineering, utilities, and rail have the right to decline to carry out work if they feel it is not safe to do so. 

Our vision is:

All our operations should be healthy, safe, and sustainable for our people and our planet. 

All persons carrying out work on behalf of OCU are actively encouraged, through the company Safety Behavioural Programme ‘Mindset’ to stop work and report to their Line Manager/Supervisor any issue or matter that may place them or the health and safety of others at risk. 

Any situation which leads to an individual refusing to work for health and safety reasons shall be reported to: 

• The most senior person on site immediately, and in the event of a mutually acceptable solution not being agreed at site level, to the Head of SHE or (in their absence) the Business Units Senior Operations Director who shall undertake a review and their decision will be final. 

All refusals to work will be responded to positively and promptly. They shall be reported and investigated in accordance with the company’s Incident and Accident Reporting process. The employee raising the work safety matter will be informed of the decisions throughout the process. 

Refusal to work on the grounds of health and safety is free from any disciplinary action. OCU will not discipline, discharge, suspend, lay off or demote an employee or impose any financial or other penalty on an employee who invokes this Policy. 

All employees and those working on our behalf will know about this policy. We will ensure it is visible and displayed at all our locations and on the company intranet. The Board of Directors fully supports this Policy and shall ensure it is communicated, implemented, and reviewed at least once a year.