It is the policy of Verrus to conduct business in an honest and ethical manner. As part of that, Verrus takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships, wherever it operates, and implementing and enforcing effective systems to counter bribery.
Verrus will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which it conducts business, including the UK Bribery Act 2010, which applies to conduct both in the UK and abroad.
This policy applies to all individuals working for or on behalf of Verrus at all levels and grades, whether permanent, fixed term or temporary, and wherever located, including consultants, contractors, seconded staff, casual staff, agency staff, volunteers, agents, sponsors and any other person who performs services for or on behalf of Verrus, (collectively referred to as Workers in this policy).
In this policy, Third Party means any individual or organisation that Workers come into contact with during the course of work and the running of Verrus’s business, and includes actual and potential clients, intermediaries, referrers of work, suppliers, distributors, business contacts, agents, advisers, government and public bodies (including their advisers, representatives and officials), politicians and political parties.
A bribe is an inducement or reward offered, promised or provided in order to improperly gain any commercial, contractual, regulatory or personal advantage, which may constitute an offence under the UK Bribery Act 2010, namely:
- Giving or offering a bribe
- Receiving or requesting a bribe
- Bribing a foreign public official
Verrus may also be liable under UK Bribery Act 2010 if it fails to prevent bribery by an associated person (including but not limited to Workers) for Verrus’s benefit.
This policy does not prohibit normal and appropriate gifts and hospitality (given and received) to or from Third Parties unless otherwise specifically stated. However, we have specific internal policies and procedures which provide guidance to Workers as to what is to be regarded as normal and appropriate gifts and hospitality in terms of financial limits, subject to the principles set out below, namely that any gift or hospitality:
- Must not be made with the intention of improperly influencing a Third Party or Employee to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits
- Must comply with local law in all relevant countries
- Must be given in the name of the organisation, not in an individual’s name
- Must not include cash or a cash equivalent
- Must be appropriate under the circumstances
- Must be of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift
- Must be given openly, not secretly
In the case of gifts, they must not be offered to, or accepted from, government officials or representatives, politicians or political parties, without prior approval.
Verrus appreciates that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable both in the UK and any other relevant country. The intention behind the gift should always be considered.
What is not acceptable is for any Worker (or someone on their behalf) to:
- Give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that they or Verrus will improperly be given a business advantage, or as a reward for a business advantage already improperly 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 where it is known or suspected that it is offered or given with the expectation that the Third Party will improperly obtain a business advantage
- Accept a gift or hospitality from a Third Party where it is known or suspected that it is offered or provided with an expectation that a business advantage will be improperly provided by Verrus 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
We do not make, and will not accept, facilitation payments or “kickbacks” of any kind, such as small, unofficial payments made to secure or expedite a routine government action by a government official, or payments made in return for a business favour or advantage.
Verrus only makes charitable donations and provides sponsorship that are legal and ethical under local laws and practices and which are in accordance with Verrus’s internal policies and procedures.
We keep appropriate financial records and have appropriate internal controls in place which evidence the business reason for gifts, hospitality and payments made and received.
The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All Workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.
Workers are required to notify Verrus as soon as possible if it is believed or suspected that a conflict with this policy has occurred, or may occur in the future, or if they are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that they are a victim of another form of unlawful activity.
Any employee who breaches this policy may face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with non-employee Workers if they breach this policy.
If any Third Party is aware of any activity by any Worker which might lead to, or suggest, a breach of this policy, they should contact Verrus immediately.
All Workers are aware that they are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.
Verrus recognises that all businesses have an obligation to prevent slavery and human trafficking and we do all in our power to prevent slavery and human trafficking within our business and within our supply chains.
Modern slavery can take many forms including the trafficking of people, forced labour, servitude and/or slavery. As recruitment experts, we take our responsibility for supplying staff extremely seriously and are aware of the potential for being targeted by traffickers and unlicensed gangmasters. Our own processes around candidate engagement ensure that our employees are alert to the signs of exploitation, in order that we may take the necessary action promptly and effectively should it be identified.
This statement focuses specifically on Verrus’ compliance with the Modern Slavery Act 2015 (the Act) and highlights the steps we take to ensure there is no slavery or human trafficking occurring within our organisation or its supply chains.
We expect our suppliers to aim for high ethical standards and to operate in an ethical, legally compliant and professional manner. We also expect our suppliers to promote similar standards in their own supply chain(s.)
Suppliers are expected to have in place a policy recognising, respecting and protecting the human rights of their employees, those of their suppliers and business partners, and the communities affected by the suppliers’ operations.
Employees should be free to choose to work for their employer and to leave the company upon reasonable notice.
All employees must be provided with a clear contract of employment, which complies with local legislation.
All employees must be treated in a fair and equal manner and with dignity and respect.
Any form of discrimination, victimisation or harassment on any grounds including, but not limited to, marital or civil partnership status, sex (including gender reassignment), race (including colour, ethnic and national origin, nationality), disability, sexual orientation, having or not having dependants, religious belief or political opinion, age, trade union activity and offending background should be prohibited.
All applicable laws and industry standards on employee wages, benefits, working hours and minimum age should be adhered to in all countries of operation, without any unauthorised deductions. Suppliers should observe the provisions of the International Labour Organization such that any young persons under the age of 18 should not be employed to work at night or for any hazardous work and their employment should not harm the young person’s education, health or physical, mental, moral or social development. No young persons may be employed below the age of 16.
All slavery and human trafficking laws must be complied with including, but not limited to, the UK Modern Slavery Act 2015. Suppliers must ensure their business operations are free from slavery and human trafficking practices whether in the UK or elsewhere, both internally and within their supply chains and other external business relationships. 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.
As part of our commitment to identify and eradicate slavery and human trafficking, we have in place a process to undertake due diligence on our supply chain network to ensure compliance with legislative obligations.
All Verrus employees have access to dedicated channels through which they may voice concerns, either through local reporting mechanisms or through the global whistleblowing procedure. Verrus is committed to protecting employees when disclosing malpractice and will ensure that all disclosures made in good faith will be treated confidentially and without fear of retaliation.
All staff within Verrus are expected to comply with all laws and act in accordance with local guidelines and regulations and act with integrity and honesty.
As a values-led organisation, Verrus is committed to the importance of acting ethically and in the interests of all stakeholders across the societies in which we operate. We have therefore developed this policy to outline our commitment towards:
- The people we work with: Our own employees and the candidates and clients that we work with
- The community we work in: Our commitment to the wider community within which we operate
- The world we live in: Our commitment to the environment and wider world
The people we work with
As the foundation of any strong relationship, we believe that trust lies at the heart of a great service business. And to us trust begins with strong values that underpin every interaction we have with the people and businesses we work with:
- We don’t hide behind industry jargon and complex sounding processes
- We explain what we do in the language of your world and we’re honest about what we can achieve
- We’re committed to delivering a unique experience and process that elevates our role from supplier to trusted business partner
- We’re committed to changing the face of recruitment, for good
- We attract the best people who, in turn, deliver the best service
- We always seek feedback, we measure our people by what you say, and we constantly strive for improvement
The community we work in
We aim to have a positive impact on our community and society by developing programmes and activities that allow us to contribute to the betterment of those who share them with us.
We are therefore delighted to support St Gemma’s Hospice as our designated charity. St Gemma’s Hospice, based in Leeds, is the largest hospice in Yorkshire and one of the largest in the UK. It provides care and quality of life for local people with cancer and other life-threatening illnesses.
We support St Gemma’s Hospice with:
- Dress down days to raise money which can be donated to the charity
- Sponsorship events – Multiple people within the organisation have organised sponsored sporting challenges to raise money for the charity
- Allowing our people flexibility in their working hours to incorporate fund raising activities and training for sporting challenges that will also help them achieve their personal ambitions
The world we live in
Verrus is fully committed to the principles of environmental sustainability and recognises its potential impact on the environment.
We recognise that our activities, whilst a service company, still result in the generation of waste and emissions and we commit to reducing our carbon footprint by ensuring that a responsible policy is adopted when sourcing materials and stock, and when disposing of waste products and equipment.
We promote and raise awareness of good environmental practices amongst employees, including:
- Turning off lights and electrical equipment when not in use
- Considering whether hardcopy printouts are required
- Ensuring conformance to relevant legislation
- Promoting a purchasing policy which, where practicable, favours products and services which cause the least harm to the environment
- Recycling all waste using recognised recycling facilities
- Returning empty photocopier/printer toner cartridges to the supplier or to a recognised agency for recycling
- Disposing of redundant equipment and office furniture to second-hand users
- Ensuring electrical equipment is tested on a regular basis to maintain energy efficiency as well as safety
- Maximising the use of video and telephone conferencing to reduce the need for travelling between offices
- Encouraging employees to use public transport or run/walk/cycle where feasible
This environmental policy applies to all of our operations and all employees have a responsibility to ensure that the aims and objectives of the policy are met.
As a values-led organisation, Verrus is committed to the prime importance of acting ethically in the interests of all stakeholders within the societies in which we operate.
We greatly value the differences amongst the individuals forming our candidate database and realise the importance of a diverse balance of talent for our clients. We cannot and do not recruit individuals for specific roles based on gender, age, marital status, sexual orientation, race, colour, religion or belief and our candidate database is enriched with people from highly diverse backgrounds.
We have built a brand and a reputation that acts fairly and ethically to all, and focuses on an individual’s skills & experience, potential and career aspirations – no matter what their background. Our equal opportunities statement for candidates demonstrates our commitment to equality and diversity:
Verrus is an equal opportunities employer. We are committed to providing equal opportunities to all employees and candidates. We ensure that no employee, potential employee or candidate receives less favourable treatment on the grounds of gender, marital status, sexual orientation, race, colour, religion or belief, nationality or ethnic origin.
All employees are responsible for complying with this policy and for ensuring that the standards of behaviour required by the company are fully observed.
In addition, we have signed the REC (Recruitment and Employment Confederation’s) diversity pledge. It makes a promise to act ethically on issues of diversity in all that we do. Acting against this, indeed, provides our clients and candidates a forum for complaint. This pledge is displayed in our offices to remind all consultants of how we expect them to behave.
We will not treat an employee, prospective employee or candidate less favourably for any reason relating to disability or their requirement for part time or fixed time work. We will take all reasonable steps to ensure that all disabled individuals are able to participate in our business activities on an equal basis with people who are not disabled.
All employees are responsible for complying with this policy and for ensuring that the standards of behaviour required by the company are fully observed by:
- Treating others on their merits and disassociating themselves from any form of direct or indirect discrimination, victimisation or harassment
- Bringing to the attention of their Line Manager any suspected working practice in breach of this policy
- Working together to promote a harmonious working environment free from discrimination, harassment and/or bullying
This statement has been issued to communicate our commitment to upholding the principles of the General Data Protection Regulation (GDPR) of 25th May 2018. Verrus is fully committed to protecting the privacy of every individual we engage with through:
- Only processing the personal data of individuals who have given us consent to do so
- Implementing robust operational safeguards to prevent privacy breaches
- Communicating with absolute transparency on these issues
Let’s take a closer look at the key principles of GDPR and how Verrus goes about upholding these principles to ensure that privacy and data protection are safeguarded for all:
- What is the ‘personal data’ of ‘individuals?’
This includes – but is not limited to – names, telephone numbers, email addresses and any other identifying information for people that we employ or engage with in a professional capacity.
- How do we gain consent to process individuals’ personal data?
Every individual that we formally employ or professionally engage with is required to provide their recorded verbal consent in order for us to process their personal data. Candidates’ personal data will therefore not be processed (received, stored and/or shared) by Verrus without this consent.
- From where do we receive individuals’ personal data?
The personal data of all individuals we professionally engage with is received from registrations on our company website, from specific job applications, from our employees’ professional networks and/or from third party data providers including – but not limited to – employment websites, social media and industrial directories. All individuals have the right to know where we have accessed their personal data from and we, in turn, are committed to disclosing this information with absolute transparency, also directing individuals to the specific privacy policies of our partners if required.
- What do we do with individuals’ personal data?
As recruitment consultants we process the personal data of individuals as either employers (clients) and/or potential employees (candidates.) The personal data of any candidate is not shared with or distributed to any client or other third party without the prior recorded verbal consent of that candidate. This is not only a compliance measure but an integral part of procedural best practice and quality control policy.
- For how long do we store individuals’ personal data?
The personal data of all individuals we professionally engage with is stored securely on our secure database for a maximum period of five years beyond which those individuals are contacted with the option to either re-consent to our continued processing of their personal data or to opt out with the result that their personal data will be entirely, immediately and securely deleted.
- How do we ensure the security of individuals’ personal data?
The personal data of all individuals we professionally engage with is stored ONLY on our secure database, which is protected with multi-factor authentication. Furthermore, we have implemented strict security barriers within Microsoft 365 (also multi-factor authenticated) to physically prevent the transmission by email of individuals’ personal data to non-domain email addresses other than those of the client(s) we have received (from those individuals) consent to make a formal introduction to. All Verrus staff are fully trained on GDPR compliance best practices and made contractually aware of the personal implications of human error in respect to data privacy and the seriousness with which we, as an organisation, respect individuals’ right to privacy.
- How can individuals access, amend or reclaim the personal data we have collected about them?
All individuals we professionally engage with have the right to ask us at any time for a copy or record of the personal information we have collected about them or to request amendment or immediate deletion of this information, irrespective of our standard five-year processing period. We will however ask for you to first provide sufficient verification before we are able to process such a request.
- How do we delete individuals’ personal data?
The personal data of all individuals we professionally engage with who have not re-consented to our continued processing of their personal data after five years – or who have requested immediate removal for whatever reason – is securely deleted from our secure database with immediate effect. Any corresponding non-digital (paper) records of individuals’ personal data are disposed of securely by Shred-It UK (a member of the National Association for Information Destruction) on a weekly basis, as part of our quarterly data protection audits or with immediate effect if requested by the individual.