Charles Hollywood

Code of business practice

1. Purpose
   Since it was started in 1987 Charles Hollywood has, through the diligence and commitment of its Directors and employees, both past and present, built a reputation for conducting its business with honesty and integrity. This reputation is a valuable asset: once lost, it would be extremely difficult and take a long time to regain.
   

   The Board considers that it is vital to the continued success of Charles Hollywood that we protect our reputation by conducting our business with honesty and integrity and in compliance with all applicable legal and regulatory requirements. This Code of Conduct sets out the fundamental standards to be followed by all Directors and employees throughout the Group and seeks to promote honest and ethical conduct when acting on behalf of the Company.

Employees should:

2.1 Conduct the Company’s business with honesty and integrity and in a professional manner that protects the Company’s public image and reputation.

Employees should exercise care and good judgment when dealing with the receiving of entertainment, gifts or benefits and should remain scrupulously free from obligations to suppliers or customers. A good benchmark to enable you to judge whether any proposed action is appropriate, is to ask yourself whether the Company or the recipient would be embarrassed if the event should become public knowledge. The following are some guidelines on what is appropriate and what is not:

• Gifts of cash, or cash equivalents, are never permissible regardless of the amounts.
• Gifts, services, entertainment or benefits of any kind from the Company’s suppliers will be permitted only where they are considered normal in the course of carrying out your duties. Should something be offered which is out of the ordinary, or if you are in any doubt whatsoever, you must seek approval from a senior member of management before the gift, entertainment, etc. is accepted.
• The Company will only fund gifts and entertainment where they are consistent with accepted business practice.
• Bribery in any form is not acceptable.
• Build relationships with customers, suppliers and fellow employees based on trust and treat every individual with respect and dignity in the conduct of Company business.
• Become familiar with and comply with relevant legal requirements and Company policy and procedures.

2.3 All employees having dealings with suppliers or contact with competitors should be conversant with the principles set out in the Competition Act 1998 and the Enterprise Act 2002. This legislation outlaws anti-competitive agreements and conduct and is designed to establish a level playing field for all businesses engaged in a particular sphere of activity. Penalties for breaching the legislation are severe. Examples of practices which are prohibited include:

• price fixing;
• market-sharing;
• the imposition of unfair terms and conditions;
• any practices which may be perceived to be an abuse of a dominant market position;
• restricting a competitors source of supply.
  

No employee should agree on, or even discuss with competitors product pricing, market sharing or terms and conditions relating to products offered by the Company. The law in this area is complex: if in doubt, employees should seek advice from the Group Secretary before engaging in any discussions or meetings on matters which may be prohibited by the Competition legislation.

2.4 Avoid actual or potential conflicts of interest with the Company, or the appearance thereof, in all transactions.

Any employee who has a personal interest in an organisation with which Charles Hollywood has or may have a business relationship is vulnerable to allegations of impropriety. If a personal interest or that of a member of one’s immediate family might influence the Company’s business relationship, it should be declared in writing to the Group Secretary. A copy of this should also be sent to the Managing Director of the Company in which the individual is employed.

Examples of a personal interest that should be declared include a directorship, a significant shareholding, a promise of future employment or the employment of a close relative or friend in a position of influence in an organisation which may be given business or awarded contracts by our Company.

Similarly, the employment of a close relative or friend within the Company should be done in such a way that a conflict of interest does not arise.

The policy of the Company with respect to conflicts of interest requires that all employees avoid situations in which any conflict might arise between their personal interest and those of the Company in dealing with suppliers, customers and all other organisations or individuals, doing or seeking to do business with the Company.

If you are in any doubt as to whether a conflict of interest exists or may develop, you should raise this immediately with the Group Secretary or a senior member of management.

2.5. Safeguard the Company’s confidential information, and respect the confidential information of other parties with whom the Company has dealings.

All employees have a responsibility to safeguard the confidentiality of any information acquired during the course of their work, including information kept on computers, and a duty never to use it for personal advantage. Such information should not be disclosed outside the Company and should only be divulged to other staff who need to know the information in order to carry out their duties. This obligation applies not only during employment with the Company, but thereafter as well.

2.6. Promptly report to the Company any breaches of law or ethical principles or Company policies that come to the employee’s attention, and cooperate fully in any audit, enquiry, review or investigation by the Company. This includes improper use of Company assets, fraud and theft: such conduct will always be treated as gross misconduct which can result in immediate termination of employment.

It is important, however, that by doing so there is no suggestion to a third party that the employee is acting on behalf of, or with the support of, his or her individual business or Northgate plc.

To avoid any misunderstanding, no employee should permit his or her company affiliation to be noted in any outside organisation’s materials or activities without the express written approval of a member of senior management.

Equal opportunities policy

We are committed to the principle of equal opportunity in employment.

Accordingly, our employment policies for recruitment, selection, training, development and promotion are designed to ensure that no job applicant or employee receives less favourable treatment on the grounds of race, colour, nationality, ethnic or national origin, disability, trade union membership or non-membership, sex, marital status, sexual orientation, religion, age or working part time. The objective of this policy is to ensure that individuals are selected, promoted and otherwise treated solely on the basis of their relevant aptitudes, skill and abilities.
Management has the primary responsibility for the successful implementation of the policy by:

• Not discriminating in the course of employment against fellow employees or job applicants.
• Not inducing or attempting to induce others to practise unlawful discrimination.
• Bringing to the attention of employees that they will be subject to disciplinary action for failure to adhere to the policy.
  

Individual employees have the responsibility to ensure that they assist the Company in achieving these objectives by:

• Not discriminating in the course of employment against fellow employees, customers, suppliers or members of the public with whom they come into contact during the course of their duties.
• Not inducing or attempting to induce others to practice unlawful discrimination.
• Reporting any discriminatory action to the Managing Director.
  

The successful operation of this policy necessitates a contribution from each employee and all employees have an obligation to report any act of discrimination known to them.

Employees who consider that they are a victim of unlawful discrimination may raise the issue through the Grievance Procedure.

Heath, Saftety and Welfare

The Health & Safety at Work etc, Act 1974 imposes a statutory duty on employers to ensure in so far as is reasonably practicable the health and safety of their employees whilst at work. This duty also extends to others who may be affected by our activities.

Employees also have a statutory duty to care for themselves and others who may be affected by their acts or omissions.

To enable these duties to be carried out, Charles Hollywood will ensure that responsibilities for health and safety matters are effectively assigned, accepted and fulfilled at all levels within the Group.

1. We will, so far as is reasonably practicable, ensure that:
   
   • Adequate resources are provided to ensure that proper provision can be made for health and safety
   • Risk assessments are carried out and periodically reviewed
   • Systems of work are provided and maintained that are safe and without risks to health
   • Arrangements for use, handling, storage, and transport of articles and substances for use at work are safe and without risks to health
   • All employees are provided with such information, instruction, training and supervision as is necessary to secure their safety and health at work and the safety of others who may be affected by their actions
   • The provision and maintenance of plant, machinery and equipment is safe and without risk to health
   • The working environment of all employees is safe and without risk to health and adequate provision is made with regard to the facilities and arrangements for their welfare at work
   • The place of work is safe and there is safe access to and egress from the work place
   • Monitoring activities are undertaken to maintain agreed standards.
     
     
2. It is the duty of all employees at work:
   
   • To take reasonable care for the health and safety of themselves and other persons who may be affected by their acts or omissions at work and co-operate with the company in fulfilling it’s statutory duties
   • Not to interfere or misuse anything provided in the interest of health and safety
3. General:
   
   • This Health and Safety Policy will be reviewed periodically, amended and updated as and when necessary. Any changes will be effectively communicated to all employees

Detailed polices and procedures are readily available for review by employees.

Training policy

1. We acknowledge the essential need to provide appropriate and systematic training and development for our employees. All employees will be encouraged to maximise their potential to achieve job satisfaction and reach the highest standard of efficiency and competence.
   
   
2. It is our policy to provide a programme of induction training for new employees. The basis of this will be ‘on-the-job’ training, supervised by the immediate Supervisor or Manager.
   
   
3. Further development is normally achieved by experience, with which knowledge and capability is extended. This may be aided by appropriate formal training (external or in-house), in accordance with regularly assessed training needs.
   
   
4. An individual may be included in training programmes in one of the following ways:
   By the recommendation of their immediate Manager because of a requirement for a training need relating to groups of employees arising from legislative, technological or similar external factors which require additional specialist expertise.
   
   
5. It is our policy to ensure that special attention to safety training is provided, both at the induction stage and subsequently.
   
   
6. Employees are encouraged to benefit from attaining further education facilities which provide additional knowledge and/or qualifications relevant to their work. Accordingly, financial assistance may be provided in connection with attendance at approved evening classes or in the assessment and registration for a vocational qualification.
   
   
7. In order to carry out this policy, we will allocate sufficient resources to achieve the objectives set.