Bluestones Medical Complex Care maintains a comprehensive set of policies that govern the way we work with our clients and candidates. We’ve included links to those policies from this page.
Where referenced, “The Company” refers to Bluestones Medical Complex Care.
Bluestones Medical Complex Care is a subsidiary of Bluestones Investment Group.
- It is the policy of Bluestones Medical Complex Care to conduct all of our business in an honest and ethical manner.
- Bluestones Medical Complex Care takes its responsibilities under the Bribery Act 2010 very seriously. If found to be in breach of the Bribery Act 2010, it may result in up to ten years’ imprisonment and/or an unlimited fine and considerable reputational damage. In addition, Bluestones Medical Complex Care may also be debarred from participation in public tenders. Given the nature of its business, it is essential that Bluestones Medical Complex Care takes a zero-tolerance approach to bribery and corruption.
- Bluestones Medical Complex Care requires all staff and volunteers to act honestly and with integrity at all times in order to comply with safeguarding obligations.
- This policy is essential to ensure that Bluestones Medical Complex Care can demonstrate it has adequate procedures in place in order to prevent bribery.
- It is the individual person’s responsibility to read and be confident that they understand and fully comply with this policy. In any area of doubt, Darren Logue must be approached to provide a further explanation.
What is Bribery?
A bribe is something that is offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
An advantage includes money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or anything else of value.
What is Not Acceptable?
It is not acceptable for an individual engaged by Bluestones Medical Complex Care (or someone on their behalf) 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 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 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
- Engage in any activity that might lead to a breach of this policy
- Facilitation payments may be experienced where a Service User, relative or other agent offers a payment to obtain a level of service for a Service User that would not normally be provided. We do not make and will not accept facilitation payments or “kickbacks” of any kind. Kickbacks are typically payments made in return for favour or advantage. Our absolute policy is that such payments are not to be accepted and should be reported to Darren Logue.
- All workers must avoid any activity that might lead to or suggest that a facilitation payment or kickback will be made or accepted. If staff are asked to make a payment on behalf of Bluestones Medical Complex Care, staff must always be mindful of what the payment is for and whether the amount requested is proportionate to the service or goods provided. Staff must always obtain a receipt detailing the reason for the payment.
- If staff have any suspicions or concerns, they must raise them directly with the line manager, or where this is not appropriate, any other manager/senior employee.
- During any form of tendering process gifts and hospitality (even if proportionate) must not be accepted, and if offered, should be politely declined and referred to Darren Logue.
- Reasonable and proportionate gifts, as a token of appreciation or as part of facilitating normal business relationships are acceptable; the key is that they must not be an inducement to act improperly.
- If staff receive a gift they must report it to their line manager and complete the Gift and Hospitality Register, providing details of the gift, its worth, whether it has been accepted (and if so, the reasons for this).
Bluestones Medical Complex Care is committed to protecting and respecting your privacy.
Any references to “we”, “us”, “our” means Bluestones Medical Complex Care Limited as defined in section 1159 of the UK Companies Act 2006.
This notice together with our Data Retention Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
The UK General Data Protection Regulation (UK GDPR) (Regulation (EU) 2016/679) has been directly incorporated into UK law sitting alongside the Data Protection Act 2018 (“DPA”) and aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
We will comply with UK GDPR and the DPA which means your data will be:
- Used lawfully, fairly and in a transparent way;
- Collected only for valid purposes that we have clearly explained to you and not used in a way which is incompatible with those purposes;
- Relevant to the purposes we have told you about and limited to only those purposes;
- Accurate and kept up to date;
- Kept only as long as necessary for the purposes we have told you about;
- Kept securely.
Please read the following carefully to understand more detail our views and practices regarding your personal data and how we will treat it.
For the purposes of data protection legislation in force from time to time our nominated representative is our Shared Services Director.
Who we are and what we do
Bluestones Medical Complex Care Limited is a recruitment agency operating in the healthcare industry. We collect the personal data of the following types of people to allow us to undertake our business;
- Prospective and placed candidates for permanent or temporary roles;
- Prospective and live client contacts;
- Supplier contacts to support our services;
- Employees, consultants, temporary workers;
We collect information about you to carry out our core business and activities.
Information you give to us, or we collect about you.
This is information about you that you give us by filling in forms on our site bluestonesmedicalcomplexcare.co.uk (our site) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site.
The information you give us, or we collect about you may include your name, address, private and corporate e-mail address and phone number, financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the United Kingdom, curriculum vitae and photograph, links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, business Facebook or corporate website.
You may also give us, or we may collect or store more sensitive personal data such as information about your race, ethnicity, religious beliefs, sexual orientation, political opinions, health (including any medical condition, health and sickness records) or information about criminal convictions or offences.
Information we collect about you when you visit our website.
With regard to each of your visits to our site we will automatically collect the following information:
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information if applicable, browser type and version.
- Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
Information we obtain from other sources.
This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, personal recommendations. In this case we will inform you, by sending you this privacy notice, within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from and whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
We are working closely with third parties including, business partners, sub-contractors in technical, professional, payment and other services, advertising networks, analytics providers, search information providers, credit reference agencies and professional advisors. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
Purposes of the processing and the legal basis for the processing
We use information held about you in the following ways:
To carry out our obligations arising from any contracts we intend to enter into or have entered into between you and us and to provide you with the information, products and services that you request from us, or we think will be of interest to you because it is relevant to your career or to your organisation.
To provide you with information about other goods and services we offer that are similar to those that you have already purchased, been provided with, or enquired about.
The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of temporary or permanent engagement. However, our service expands to supporting individuals throughout their career.
Our legal basis for the processing of personal data is our legitimate interests, described in more detail below, although we will also rely on contractual obligations to which you are subject, legal obligations and consent for specific uses of data.
We will rely on contractual obligations if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation.
We will rely on legal obligation in some cases, where we are required by law or regulation to process your data.
We will in some circumstances rely on consent for particular uses of your data. Where we rely on consent, you will be asked for your express consent. An example of when we will rely on consent as the legal basis for processing your data is when we process your data for marketing purposes.
Our Legitimate Interests
Our legitimate interests in collecting and retaining your personal data is described below:
As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment, temporary worker placements or independent professional contracts. The exchange of personal data of our candidates and our client contact details is a fundamental part of this process.
In order to support our candidates’ career aspirations and our clients’ resourcing needs, we require a database of candidate and client personal data. The database will contain historical information as well as current resourcing requirements.
To maintain, expand and develop our business we need to record the personal data of prospective candidates and client contacts.
Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system. Where consent is the lawful basis for our processing you have the right to withdraw your consent to this particular processing at any time.
Other Uses we will make of your data:
We will also use your data:
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To improve our site to ensure that content is presented in the most effective manner for you when you are using your computer or other devices;
- To notify you about changes to our service;
- To allow you to participate in interactive features of our service, when you choose to do so;
- As part of our efforts to keep our site safe and secure;
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- To make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
We do not undertake automated decision making or profiling. We use our computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process.
Do you have to provide us with personal data?
You may refuse to give us your personal and sensitive personal data. Furthermore, you have the right to ask us to delete, change or stop processing your data that we have already received or collected. If you do not provide us with personal or sensitive personal data, or if you request a restriction of processing however, we may not be able to provide you with the services that you have requested and that are stated in this policy.
Disclosure of your information inside and outside of the UK and the EEA
We will share your personal information with:
Any member of our group both in the UK, the EEA and outside of the EEA.
Selected third parties including:
- Clients for the purpose of introducing candidates to them;
- Candidates for the purpose of arranging interviews and engagements;
- Clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract we enter into with them or you;
- subcontractors including email marketing specialists, event organisers, payment and other financial service providers
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site;
- Credit reference agencies, our insurance broker, compliance partners and other sub-contractors for the purpose of assessing your suitability for a role where this is a condition of us entering into a contract with you.
- Third party IT providers and Group companies involved in the provision of support to the company they contract with.
We will disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If a relevant Group company or all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
The lawful basis for the third-party processing will include:
- Their own legitimate interests in processing your personal data, in most cases to fulfil their internal resourcing needs;
- Satisfaction of their contractual obligations to us as our data processor;
- For the purpose of a contract in place or in contemplation;
- To fulfil their legal obligations.
Where we store and process your personal data
The data that we collect from you may/will be transferred to, and stored at, a destination outside the UK or European Economic Area (”EEA”). It may be transferred to third parties outside of the UK or the EEA for the purpose of our recruitment services. It may/will also be processed by staff operating outside the UK or the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, our recruitment services and the provision of support services. By submitting your personal data, you agree to this processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Retention of your data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate interests and that you are happy for us to do so. Accordingly, we have a data retention policy and run data routines to remove data that we no longer have a legitimate interest in maintaining.
We do the following to try to ensure that the data we hold on you is accurate:
- prior to making an introduction we check that we have accurate information about you;
- we keep in touch with you so you can let us know of changes to your personal data;
We segregate our data so that we keep different types of data for different time periods.
The criteria we use to determine whether we should retain your personal data include:
- the nature of the personal data;
- its perceived accuracy;
- our legal obligations;
- whether an interview or placement has been arranged; and
- our recruitment expertise and knowledge of the industry by country, sector and job role.
We may store and handle your data in the following ways:
- We may archive part or all of your personal data, retain it on our financial systems only or delete all or part of the data from our main Customer Relationship Manager (CRM) system.
- We may pseudonymise parts of your data, particularly following a request for restriction or erasure of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.
For your information, Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers, or pseudonyms.
Our current retention notice is available upon request.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for marketing purposes or if we intend to disclose your information to any third party for marketing purposes. We will collect express consent from you, if legally required, prior to using your personal data for marketing purposes.
You can exercise your right to accept or prevent processing for marketing purposes by checking the boxes on the forms we provide you when we collect your data. You can also exercise the right to not have your data used for marketing purposes at any time by contacting us via the website.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliate. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The UK GDPR provides you with the right to:
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party in certain formats, if practicable.
- Make a complaint to a supervisory body which in the United Kingdom is the Information
Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns
Access to information
The Data Protection Act 2018 and the UK GDPR give you the right to access information held about you. We also encourage you to contact us to ensure your data is accurate and complete. Your right of access can be exercised in accordance with the Act and the UK GDPR.
A subject access request should be submitted to email@example.com
No fee will apply unless the requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character. In such circumstances, we may charge a fee or refuse to act on the request.
Changes to our privacy notice
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to firstname.lastname@example.org
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 in order 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 has 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 will 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/temporary worker is submitted for a vacancy or assignment, or in any terms of employment or terms of engagement for temporary workers. The Company will ensure that each candidate is assessed in accordance with the candidate’s merits, qualifications, and ability to perform the relevant duties for the role.
Under the Act unlawful discrimination occurs in the following circumstances:
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 that has the protected characteristic.
Direct discrimination would also occur if a recruitment consultancy accepted and acted upon instructions from an employer which state that certain persons are unacceptable due to a protected characteristic unless an exception applies. The Act contains provisions that permit specifying a requirement that an individual must have a particular protected characteristic in order to undertake a job. These provisions are referred to as occupational requirements.
Where there is an occupational requirement then the client must show that applying the requirement is a proportionate means of achieving a legitimate aim, i.e. the employer must be able to objectively justify applying the requirement. An occupational requirement does not allow an employer to employ someone on less favourable terms or to subject a person to any other detriment.
Neither does an occupational requirement provide an excuse against harassment or victimisation of someone who does not have the occupational requirement.
Indirect discrimination occurs when a provision, criterion, or practice (PCP) is applied but this results in people who share a protected characteristic being placed at a disadvantage in comparison to those who do not have the protected characteristic. 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.
If the vacancy requires characteristics that amount to an occupational requirement or the instruction is discriminatory but there is an objective justification, The Company will not proceed with the vacancy unless the client provides written confirmation of the occupational requirement, exception, or justification.
The Company will use its best endeavours to comply with the Act and will not accept instructions from clients that will result in unlawful discrimination.
Under the Act, harassment is defined as unwanted conduct that relates to a protected characteristic that has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating, or offensive environment for that individual. This includes unwanted conduct of a sexual nature.
The Company is committed to providing a work environment free from unlawful harassment.
The Company will ensure that the consultants do not harass any individual.
Examples of prohibited harassment are:
- verbal or written conduct containing derogatory jokes or comments;
- slurs or unwanted sexual advances;
- visual conduct such as derogatory or sexually orientated posters;
- photographs, cartoons, drawings or gestures which some may find offensive;
- physical conduct such as assault, unwanted touching, or any interference because of sex, race, or any other protected characteristic basis;
- threats and demands to submit to sexual requests as a condition of continued employment or to avoid some other loss, and offers of employment benefits in return for sexual favours;
- retaliation for having reported or threatened to report harassment.
If an individual believes that they have been unlawfully harassed, they should make an immediate report to The Company followed by a written complaint as soon as possible after the incident. The details of the complaint should include:
- Details of the incident
- Name(s) of the individual(s) involved
- Name(s) of any witness(es)
The Company will undertake a thorough investigation of the allegations. If it is concluded that harassment has occurred, remedial action will be taken.
All employees and workers will be expected to comply with The Company’s policy on harassment in the workplace. Any breach of such a policy will lead to the appropriate disciplinary action.
Any individual who The Company finds to be responsible for harassment will be subject to the disciplinary procedure and the sanction may include termination.
Under the Act, victimisation occurs when an individual is treated unfavourably because he/she has done a ‘protected act’ which is bringing a claim for unlawful discrimination or raising a grievance about discrimination, or giving evidence in respect of a complaint about discrimination.
The Company will ensure that the consultants do not victimise any individual.
Discrimination occurs when a person is treated unfavourably as a result of their disability.
Indirect discrimination occurs where a provision, criterion or practice is applied by or on behalf of an employer, or any physical feature of the employer’s premises places a disabled person at a substantial disadvantage in comparison with persons who are not disabled.
In recruitment and selection, there may be a requirement to make reasonable adjustments. For example, it might be necessary to have different application procedures for partially sighted or blind applicants that enable them to use Braille. With testing and assessment methods and procedures, tests can only be justified if they are directly related to the skills and competencies required for the job. Even then, it might be appropriate to have different levels of acceptable test results, depending on the disability. For example, an applicant with a learning disability might need more time to complete a test, or not be expected to reach the same standard as other non-disabled applicants.
Reasonable adjustments in recruiting could include:
- modifying testing and assessment procedures;
- meeting the candidate at alternative premises which are more easily accessible;
- having flexibility in the timing of interviews;
- modifying application procedures and application forms;
- providing a reader or interpreter.
Wherever possible The Company will make reasonable adjustments to hallways, passages, and doors in order to provide and improve means of access for disabled employees and workers. However, this may not always be feasible, due to circumstances creating such difficulties as to render such adjustments as being beyond what is reasonable in all the circumstances.
The Company will not discriminate against a disabled person:
- in the arrangements i.e. application form, interview or arrangements for selection for determining whom a job should be offered; or
- in the terms on which employment or engagement of temporary workers is offered; or
- by refusing to offer, or deliberately not offering the disabled person a job for reasons connected with their disability; or
- in the opportunities afforded to the person for receiving any benefit, or by refusing to afford, or deliberately not affording him or her any such opportunity; or
- by subjecting the individual to any other detriment (detriment will include refusal of training or transfer, demotion, reduction of wage, or harassment).
The Company will make career opportunities available to all people with disabilities and every practical effort will be made to provide for the needs of staff, candidates, and clients.
Under the Act, it is unlawful to directly or indirectly discriminate against or to harass or victimise a person because of age. Age discrimination does not just provide protection for people who are older or younger. People of all ages are protected.
A reference to age is a reference to a person’s age group. People who share the protected characteristic of age are people who are in the same age group.
Age groups can have various references:
- Under 21s
- People in their 40s
The Company will not discriminate directly or indirectly, harass or victimise any person on the grounds of their age. We will encourage clients not to include any age criteria in job specifications and every attempt will be made to encourage clients to recruit on the basis of competence and skills and not age.
The Company is committed to recruiting and retaining employees whose skills, experience, and attitude are suitable for the requirements of the various positions regardless of age. No age requirements will be stated in any job advertisements on behalf of the company.
If The Company requests age as part of its recruitment process such information will not be used as selection, training, or promotion criteria or in any detrimental way and is only for compilation of personal data, which the company holds on all employees and workers and as part of its equal opportunities monitoring process. In addition, if under the age of 22, you must adhere to the Conduct of Employment Agencies and Employment Business Regulations 2003 and other relevant legislation applicable to children or young candidates.
Where a client requests age or date of birth, this will have to be under an occupational requirement or with an objective justification which should be confirmed in writing.
This policy also covers the treatment of those employees and workers who work on a part-time basis, The Company recognises that it is an essential part of this policy that part-time employees are treated on the same terms, with no detriment, as full-time employees (albeit on a pro-rata basis) in matters such as rates of pay, holiday entitlement, maternity leave, parental and domestic incident leave and access to our pension scheme. The Company also recognises that part-time employees must be treated the same as full-time employees in relation to training and redundancy situations.
Gender reassignment policy
The Company recognises that any employee or worker may wish to change their gender during the course of their employment with the Company.
The Company will support any employee or worker through the reassignment.
The Company will make every effort to try to protect an employee or worker who has undergone, is undergoing, or intends to undergo gender reassignment, from discrimination or harassment within the workplace.
Where an employee is engaged in work where the gender change imposes genuine problems The Company will make every effort to reassign the employee or worker to an alternative role in the Company, if so desired by the employee.
Any employee or worker suffering discrimination on the grounds of gender reassignment should have recourse to the Company’s grievance procedure.
Recruitment of ex-offenders
Where The Company has registered with the Disclosure and Barring Service (DBS) and has the authority to apply for criminal records checks on individual because they are working with children or vulnerable adults or both, we will comply with the DBS’s Code of Practice which includes having a policy on the recruitment of ex-offenders.
Complaints and monitoring procedures
The Company has in place procedures for monitoring compliance with this policy and for dealing with complaints of discrimination. These will be made available immediately upon request. Any discrimination complaint will be investigated fully.
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 training 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 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, so far as reasonably practicable.
COVID-19 policy – updated June 2020
Due to the exceptional circumstances surrounding the worldwide COVID-19 pandemic, this health and safety policy has been updated to include specific arrangements, actions, and guidance relating to health and safety in our workplaces.
The health and safety of our employees is critically important, so we have adopted a three stage approach to ensuring our workplaces are safe for our workers. These stages can be summarised as follows:
- Risk assessment – completed by the branch manager or brand/divisional director to assess the office environment against a range of key criteria, as recommended by the Government.
- Awareness – once the risk assessment has been completed, a COVID-19 poster will be signed by the branch manager/divisional director and displayed prominently in the office, confirming the following:
- A COVID-19 risk assessment has been carried out and the results shared with the people who work there.
- Cleaning, handwashing and hygiene procedures have been reviewed and updated, where appropriate, to ensure they’re in line with current guidance.
- All reasonable steps have been taken to help people work from home.
- Where working from home is not possible, all reasonable steps have been taken to maintain a 2m distance in the workplace.
- Where people cannot be 2m apart, everything practical has been done to manage and minimise transmission risk.
- Individual questionnaires – the final stage sees every individual worker complete a questionnaire confirming they’ve seen the risk assessment and understand the various steps that have been taken to ensure the health and safety of workers is protected,
Completed risk assessments and individual questionnaires are sent to the Group’s head office for central collation and record keeping.
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 carried out 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 of our clients.
In accordance with Government guidelines the Company has implemented workplace Risk Assessments for the prevention of COVID-19 and social distancing measures in place in line with the government directive.
The Company is committed to ensure the health, safety & wellbeing of all staff in line with government guidance and legislation and will continue to meet with legislative obligation in line with government updates and developments.
It is the Company’s policy, so far as is reasonably practicable to:
- where working from home is not possible, workplaces will make every reasonable effort to comply with social distancing guidelines set out by the government (keeping people 2m apart wherever possible).
- ensure the workplace has sufficient cleaning, handwashing and hygiene procedures in line with the prevention of COVID-19 Company procedures and workplace Risk Assessment requirements.
- managing third party visits to the premises via remote connection and site guidance to reduce risks.
- provide and maintain facilities, equipment, and systems of work that are safe and without risks to health;
- make arrangements for ensuring safety and absence of risks to health in connection with the use, handling, storage and transport of articles and substances;
- provide such information, instruction, training and 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;
- provide such protective equipment as is necessary for the health and safety at work of employees and visitors;
- encourage staff to set high standards of health and safety by personal example and to instil an attitude of mind which accepts good health and safety practice as normal;
- monitor the effectiveness of health and safety provisions within The Company;
- and to keep the Health & Safety Policy under regular review and to duly publish any amendments.
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.
Management, staff and operatives 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 carry out their defined responsibilities. A copy of all related policies will be held in the HR department and will be made available to all employees.
Employees are expected and encouraged to be proactive on health and safety issues as part of the continued development of the health and safety culture of the organisation and the manual describes the arrangements for employee consultation and feedback.
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.
The Company will provide appropriate training and make available competent health and safety advice and adequate resources including time and money so that legal obligations may be met.
This policy will be audited for its effectiveness and it will be reviewed on a regular basis.
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.
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.
Line 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) and supervisors within the company shall be:
- To read and understand the company’s safety policy and to ensure that its provisions are being effectively carried out.
- To bring the provisions of this policy, in so far as they affect the personnel, to the attention of the employees under the control of particular 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 machinery, 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 general 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 fire-fighting 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.
Individual employees have a duty to carry out their work in a safe manner in order 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.
Monitoring the Health and Safety Policy
Monitoring the effectiveness of The Company’s policies on health and safety commences is a Board responsibility. Monitoring includes ensuring that Health & Safety audits and risk assessments are taking place regularly so that the hazards and risks of activities carried out within The Company are being adequately recognised and controlled.
Monitoring also makes sure that any deficiencies in health and safety performance are identified and that remedial action is recommended and pursued.
The provision of information, instruction and training to all staff (especially new employees) are matters that should also fall within the monitoring exercise.
The Health and Safety Committee assists to carry out the monitoring function effectively via the provision of paper and computer-based monitoring tools, such as model checklists, which individual branches and sites may adapt to their own requirements.
Monitoring of any accidents, incidents and instances of occupational ill-health occurring at branch or site level is particularly important so that remedial action can be taken to prevent any recurrence. The Health and Safety Committee will monitor all reported accidents, incidents and occupational ill-health in order to determine those events that are legally reportable to the relevant enforcing authority, and those which require further investigation and possible notification to others within the Company, and to set in train appropriate remedial action.
Any amendments will be notified by revision of this document.
Modern Slavery Act Compliance Statement
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 2022. This Statement has been approved by the Board of Directors of Bluestones Investment Group Limited (Bluestones).
Operating primarily in the UK, Bluestones employs over 230 people across 27 locations. Bluestones is a human capital investment company, with the subsidiary businesses within the 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 2022 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:
- 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)
- We conduct internal audits on our recruitment process (and those of our subsidiaries) to ensure that we only engage eligible workers for agency work.
- 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.
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.
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 Head of Legal, 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.
Bluestones Medical Complex Care is committed to developing and adopting a proactive approach to tackling hidden labour exploitation.
Hidden labour exploitation is an abuse of job applicants or workers by third-party individuals or gangs other than the employer or labour provider including rogue individuals working within these businesses but without the knowledge of management.
It includes forced labour and human trafficking for labour exploitation; payment for work-finding services and work-related exploitation such as the forced use of accommodation.
It is understood that it is often well hidden by the perpetrators with victims if they perceive themselves as such, reluctant to come forward.
- Designate appropriate managers to attend “Tackling Hidden Labour Exploitation” training and to have responsibility for developing and operating company procedures relevant to this issue.
- Accept that job finding fees are a business cost, and will not allow these to be paid by job applicants. We will not use any individual or organisation to source and supply workers without confirming that workers are not being charged a work-finding fee.
- Ensure that all staff responsible for directly recruiting workers are aware of issues around third-party labour exploitation and signs to look for and have signed appropriate Compliance Principles.
- Ensure that labour sourcing, recruitment and worker placement processes are under the control of trusted and competent staff members.
- Adopt a proactive approach to reporting suspicions of hidden worker exploitation to the Gangmasters Labour Abuse Authority and police if Modern Slavery is suspected.
- Provide information on tackling “Hidden Labour Exploitation” to our workforce through workplace posters, Intranets, induction, etc.
- Encourage workers to report cases of hidden third party labour exploitation, provide the means to do so and investigate and act on reports appropriately.
- Positively encourage and support employees and agency workers to report such exploitation which may be occurring within their communities and inform the best ways how to do report any case.
- Require labour providers and other organisations in the labour supply chain to adopt policies and procedures consistent with the above.
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.
You will use the website for lawful purposes only.
You should note that The Company provides links to websites 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.
Unless otherwise stated, the copyright and similar rights in this website 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.