OCU does not tolerate, permit, or engage in bribery, corruption, or improper payments of any kind in our business dealings, anywhere in the world, both with public officials and people in the private sector. Ethical behavior is in the long-term interests of our company.
Any concerns relating to a breach of the Policy should be reported to your Line Manager, HR Manager or a Director. Where a breach of the Policy is noted, this will be thoroughly investigated by a member of the Board who is not directly responsible for the individual under investigation. Where a conflict may still exist, a senior member of the Management team from our Parent company will be engaged to carry out the investigation. This will be facilitated by the Managing Director. We will ensure that this Policy is pursued throughout the organisation and will give full backing to the HR Team whose function 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.
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:
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.
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.
That all our operations are healthy, safe and sustainable for our people and our planet.
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.
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.
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:
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:
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.
All employment policies and arrangements have a bearing on equality of opportunity. The company policies will be reviewed regularly, and any discriminatory elements removed.
The company attaches particular importance to the needs of disabled people. Under the terms of this Policy, the Senior Management Team is required to:
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.
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.
The effectiveness of this Policy and associated arrangements will be reviewed annually under direct Supervision of the Company Managing Director.
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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.
That all our operations are healthy, safe and sustainable for our people and our planet.
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.
Click here to download the statement in full.
We are committed to improving our practices to combat slavery and human trafficking. 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.
OCU Group Limited provides design, build, installation and maintenance services across Energy, Telecoms, Water and Transport. We operate throughout the UK & Ireland based from our Head Office in Manchester and through our national network of offices and operational premises.
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.
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.
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:
We have in place systems to:
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:
We seek to monitor any risk areas and encourage anyone to report any concerns regarding supplier activities.
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 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, subcontractors and suppliers.
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:
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.
This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year ending 30 April 2023.
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.
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.
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.
This UK Tax Strategy applies to the OCU Group of companies (“the Group”) for the accounting period ended 30 April 2023. 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:
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.
Responsibility for the Group’s tax strategy, the supporting governance framework and management of tax risk ultimately sits with the Group CFO and Group Tax Manager.
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.
The Group’s tax affairs are managed by appropriately qualified individuals. Where there is uncertainty as to the application or interpretation of tax law, appropriate advice is taken from reputable professional firms.
The Group aims for certainty regarding the tax positions adopted and seeks to take advantage of available tax incentives, tax 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 in a way that gives rise to tax efficiencies providing this is aligned to the Group’s commercial objectives and complies with the associated tax legislation.
In the event the Group acquires businesses, it will seek to bring their approach to tax planning and management of tax affairs in line with the Group as soon as pragmatically possible.
The Group considers that it is prepared to accept a low level of risk in respect of UK taxation matters. We seek to be compliant with the tax laws and to 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.
OCU Group seeks to establish and maintain a transparent, collaborative, and professional relationship with HMRC. This is achieved by:
The Public Interest Disclosure Act 1998 aims to promote greater openness in the workplace and, by amending the Employment Rights Act 1996, protects ‘whistle-blowers’ from detrimental treatment, i.e., victimisation or dismissal, for raising concerns about matters they reasonably believe to be in the public interest. This statement sets out OCU Group’s Policy and provides in some detail advice and guidance to staff on the scope of the Policy. It explains that a member of staff, who has a reasonable belief that serious malpractice relating to any of the protected matters specified in the Policy has occurred or is likely to occur, may raise a concern under this procedure. There is also information about the rights of staff to raise the matter externally and the protection afforded to them if they choose to do this.
All persons employed within OCU Group are under an obligation implied in their contract of employment to give honest and faithful service to their employer. This includes an obligation not to disclose to external sources any trade secrets or confidential information acquired during the course of employment or act in a manner that will undermine the mutual trust and confidence on which the employment relationship is based. The Public Interest Disclosure Act 1998 complements those obligations by providing protection to employees for disclosures made in the public interest of certain specific types of information, which in most cases will be of a confidential nature. These are outlined below. The purpose of this policy is to provide a means by which staff are enabled to raise concerns if they have reasonable grounds for believing serious malpractice has occurred or is likely to occur. The company encourages staff to raise matters of concern responsibly through the procedures laid down in this policy statement.
The policy is designed to deal with concerns raised in relation to the specific issues which are in the public interest and are detailed below, and which fall outside the scope of other company policies and procedures. The policy is not intended to apply to personal grievances concerning an individual’s terms and conditions of employment, or other aspects of the working relationship, complaints of bullying or harassment, or disciplinary matters. Such complaints will be dealt with under existing procedures on grievance, bullying and harassment, discipline, and misconduct in research.
The policy may be used to deal with specific concerns which are in the public interest and specifically where a staff member has a reasonable belief that one of the following has occurred or is likely to occur:
If in the course of investigation any concern raised in relation to the above matters appears to the investigator to relate more appropriately to a grievance, bullying or harassment, or discipline, those procedures will be invoked, instead of or, where appropriate, in addition to this procedure.
Any member of staff who has a reasonable belief there is serious malpractice relating to any of the protected matters specified above, may raise a concern under this procedure.
The issues raised under the protected list may relate to another member of staff, a group of staff, the individual’s own department or another part of the business. The individual must reasonably believe that the relevant failure or malpractice has occurred or is likely to occur and that matter is in the public interest.
The Company will ensure that any member of staff who makes a disclosure in such circumstances will not be penalised or suffer any adverse treatment for doing so. However, a member of staff who makes a malicious or vexatious allegation without having reasonable grounds for believing that the relevant failure or malpractice has occurred, or is likely to occur, and that the matter is in the public interest may be subject to disciplinary proceedings.
In view of the protection afforded to a member of staff raising a concern about matters they reasonably believe to be in the public interest, it is hoped that individuals will feel able to put his/her name to any disclosure. The identity of the person raising the matter will be kept confidential, if so requested, for as long as possible provided that this is compatible with a proper investigation. A proper investigation may be more difficult or impossible if further information cannot be obtained from the person raising the complaint. It is also more difficult to establish whether any allegations are credible. Anonymous complaints will be investigated and acted upon as the person receiving the complaint sees fit, having regard to the seriousness of the issue raised, the credibility of the complaint, the prospects of being able to investigate the matter, and fairness to any individual mentioned in the complaint.
In many cases it will be appropriate for the member of staff to raise any concerns informally with their line manager in the first instance, either in person or in writing. It may be possible to agree a way of resolving the concern quickly and effectively.
However, where the matter is more serious, or the member of staff feels that their line manager has not addressed the concern, or they prefer not to follow that informal step for any reason, they should contact one of the following:
Jane Shelvey
HR
Tel: 02087314629
If the disclosure is about either of the above personnel, the member of staff may raise the concern with the relevant Managing Director. The person to whom the disclosure is made will decide whether the matter should be dealt with under this procedure. If he or she considers that the matter should be dealt with under a different company procedure, the person making the disclosure will be advised as to the appropriate steps which should be taken.
The person to whom the disclosure is made will normally consider the information and decide whether there is a prima facie (genuine) case to answer. He or she will decide whether an investigation should be conducted and what form it should take. This will depend on the nature of the matter raised and may be:
Some matters will need to be referred to the relevant outside body, e.g., the Police, Funding Council.
If the person to whom the disclosure is made decides not to proceed with an investigation, the decision will be explained as fully as possible to the individual who raised the concern.
Any investigation will be conducted sensitively and promptly. The employee will be notified of the intended timetable for the investigation. The person to whom the disclosure is made may authorise an initial investigation to establish the relevant facts. The investigator will report his or her findings to the person to whom the disclosure was made, who will then decide if there is a case to answer and what steps, if any, should be taken. This may include setting up a special internal independent investigation or reference to some external authority, such as the police, for further investigation. The decision may be that the matter would be more appropriately handled under existing procedures for grievance, bullying and harassment, or discipline.
Where a disclosure is made, any person or persons potentially implicated in wrongdoing will be told at an early stage and of the evidence supporting it, and they will be allowed to respond.
Should an investigation or referral conclude there has been a breach, the member, or members of staff responsible may, in addition to any civil or criminal proceedings, be subject to disciplinary action in accordance with the appropriate disciplinary procedures for the relevant category of staff.
be possible to share some of the details including, for example, specific information about any disciplinary action taken against another member of staff.
Staff should treat any information about the disclosure, the investigation, or its outcome as confidential.
If an individual is not happy with the way in which their concern has been handled or the outcome, it is open to the individual to raise this with one of the other persons specified above.
A report of all disclosures and subsequent actions taken will be made by the persons deciding on the issues. This record should be signed by the Investigating Officer and the person who made the disclosure and dated.
Where appropriate the formal record need not identify the person making the disclosure, but in such a case that person will be required to sign a document confirming that the complaint has been investigated. Such reports will normally be retained for at least five years.
The Company acknowledges the difficult choice a member of staff may have to make in raising a concern. As the issues that prompt the concern are likely to be complex, how the member of staff proceeds with his or her concern will vary from situation to situation. The following advice is recommended if a member of staff wishes to make a disclosure:
Members of staff may also wish to seek independent legal advice.
The Company accepts it has an obligation to ensure staff who make a disclosure in accordance with this policy are protected, regardless of whether or not the concern raised is upheld. A member of staff who has made a disclosure and who feels that, as a result, he or she has suffered adverse treatment should submit a formal complaint under the relevant grievance procedure for their staff group detailing what has been done to him or her.
Where it is determined there is a prima facie case that a member of staff has suffered adverse treatment, harassment, or victimisation as a result of his or her disclosure, a further investigation may take place and disciplinary action may be taken against the perpetrator in accordance with the relevant procedure.
The aim of this policy is to provide an internal mechanism for reporting, investigating, and remedying any wrongdoing in the workplace. In most cases the member of staff should not find it necessary to alert anyone externally.
The law recognises that in some circumstances it may be appropriate for you to report your concerns to certain external bodies including:
It will very rarely if ever be appropriate to alert the media.
A member of staff who makes an external disclosure of the kind described above to a Prescribed Person who reasonably believes that the information disclosed, and any allegations contained in it, are substantially true, and that the default lies within the remit of the prescribed person in question, will be protected against victimisation or other adverse treatment.Wider disclosure to any other person will only be protected if it is not made for personal gain, and the employee making the disclosure:
At OCU health and safety is a core value 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.
That all our operations are 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:
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 safe 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 be made aware of this Policy. We will ensure that it is visible; displayed at all our locations and on the company 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.
