Company Policies

Anti-Bribery Policy

Policy statement

It is the policy of Navigate Eco Solutions Limited (Navigate) to conduct business in an honest and ethical manner. As part of that, Navigate 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.

Purpose

Navigate will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which it conducts business, including, in the UK, the Bribery Act 2010 (the Act), which applies to conduct both in the UK and abroad.

Scope and applicability

This policy applies to all individuals working for or on behalf of Navigate 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 Navigate, (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 Navigate’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.

What is bribery?

A bribe is an inducement or reward offered, promised, or provided to improperly gain any commercial, contractual, regulatory, or personal advantage, which may constitute an offence under the Act, namely:

giving or offering a bribe
receiving or requesting a bribe or
bribing a foreign public official

Navigate may also be liable under the Act if it fails to prevent bribery by an associated person (including, but not limited to Workers) for Navigate’s benefit.

Gifts and hospitality

This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.

A gift or hospitality will not be appropriate if it is unduly lavish or extravagant or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).

Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers) or be given in secret. Gifts must be given in our name, not your name.

Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers, and business partners.

What is not acceptable?

It is not acceptable 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 Navigate 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 Navigate in return;
threaten or retaliate against another Worker who has refused to commit a bribery offence or who has raised concerns under this policy; or
engage in any activity that might lead to a breach of this policy.

Charitable Donations and Sponsorship

Navigate only makes charitable donations and provides sponsorship that are legal and ethical under local laws and practices and which are in accordance with Navigate’s internal policies and procedures.

Record keeping

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.

Responsibilities and raising concerns

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 Navigate 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 raise their concerns with one of the Directors (Alli Arden, Ian Cocks, Rob Arden, Dave Monks).

Monitoring and review

Navigate monitors the effectiveness and reviews the implementation of this policy at appropriate intervals, considering its suitability, adequacy, and effectiveness. Any improvements identified are made as soon as possible. Internal control systems and procedures are also subject to regular review to provide assurance that they are effective in countering any risks of bribery and corruption.

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.

Environmental Policy

Policy statement

Our policy is to reduce the impact of the businesses operations on the environment. The goal is to promote sustainability and environmental awareness at all levels of the business by:

Complying with all applicable environmental legislation and sustainability commitments
Measuring and analysing the carbon footprint of our business activities in conjunction with other climate change mitigation and adaptation efforts
Preventing pollution and reducing consumption of resources through waste management strategies that promote waste minimisation re-use, recovery, and recycling, as appropriate
Promoting and continuing to invest in technologies that provide alternatives to business travel
Adopt a procurement programme which considers the environmental impact of products and services and supports the purchase of energy-efficient products
Ensure our staff are aware of the environmental impacts of their work activities and encourage them through regular awareness and training to minimise those impacts

Equality Policy

Policy Statement

Navigate Eco Solutions Limited (Company) recognises that discrimination and victimisation is unacceptable and that it is in the interests of the Company and its employees to utilise the skills of the total workforce. It is the aim of the Company to ensure that no employee or job applicant receives less favourable facilities or treatment (either directly or indirectly) in recruitment or employment on grounds of age, disability, gender / gender reassignment, marriage / civil partnership, pregnancy / maternity, race, religion or belief, sex, or sexual orientation (the protected characteristics).

Our aim is that our workforce will be truly representative of all sections of society and each employee feels respected and able to give of their best.

We oppose all forms of unlawful and unfair discrimination or victimisation. To that end the purpose of this policy is to provide equality and fairness for all in our employment.

All employees, whether part-time, full-time, or temporary, will be treated fairly and with respect. Selection for employment, promotion, training, or any other benefit will be on the basis of aptitude and ability. All employees will be helped and encouraged to develop their full potential and the talents and resources of the workforce will be fully utilised to maximise the efficiency of the organisation.

Our staff will not discriminate directly or indirectly, or harass customers or clients because of age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, and sexual orientation in the provision of the Company’s goods and services.

This policy and the associated arrangements shall operate in accordance with statutory requirements. In addition, full account will be taken of any guidance or Codes of Practice issued by the Equality and Human Rights Commission, any Government Departments, and any other statutory bodies.

Our Commitment

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

Responsibilities of Management

Responsibility for ensuring the effective implementation and operation of the arrangements will rest with the Business Owners. The Business Owners will ensure that they and their staff operate within this policy and arrangements, and that all reasonable and practical steps are taken to avoid discrimination. Each co-founder will ensure that:

all their staff are aware of the policy and the arrangements, and the reasons for the policy
grievances concerning discrimination are dealt with properly, fairly and as quickly as possible
proper records are maintained.

The Business Owners will be responsible for monitoring the operation of the policy in respect of employees and job applicants, including periodic departmental audits.

Responsibilities of Staff

Responsibility for ensuring that there is no unlawful discrimination rests with all co-founders and the attitudes of staff are crucial to the successful operation of fair employment practices. All members of staff should:

comply with the policy and arrangements
not discriminate in their day-to-day activities or induce others to do so
not victimise, harass, or intimidate other staff or groups who have, or are perceived to have one of the protected characteristics
ensure no individual is discriminated against or harassed because of their association with another individual who has a protected characteristic
inform their manager if they become aware of any discriminatory practice

Third Parties

Third-party harassment occurs where an Navigate Eco Solutions Limited (Company) employee is harassed, and the harassment is related to a protected characteristic, by third parties such as clients or customers. Navigate Eco Solutions Limited (Company) will not tolerate such actions against its staff, and the employee concerned should inform a co-founder at once, that this has occurred. The Company will fully investigate and take all reasonable steps to ensure such harassment does not happen again.

Related Policies and Arrangements

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

Rights of Disabled People

The Company attaches particular importance to the needs of disabled people. Under the terms of this policy, managers are required to:

make reasonable adjustment to maintain the services of an employee who becomes disabled, for example, training, provision of special equipment, reduced working hours
include disabled people in training/development programmes
give full and proper consideration to disabled people who apply for jobs, having regard to making reasonable adjustments for their aptitudes and abilities to allow them to be able to do the job

Monitoring

The Company deems it appropriate to state its intention not to discriminate and assumes that this will be translated into practice consistently across the organisation. Accordingly, a monitoring system will be introduced to measure the effectiveness of the policy and arrangements.

The system will involve the routine collection and analysis of information on employees by gender, marital status, ethnic origin, sexual orientation, religion / beliefs, grade and length of service in current grade. Information regarding the number of staff who declare themselves as disabled will also be maintained.

There will also be regular assessments to measure the extent to which recruitment to first appointment, internal promotion and access to training/development opportunities affect equal opportunities for all groups.

We will maintain information on staff who have been involved in certain key policies: Disciplinary, Grievance and Bullying & Harassment.

The information collected for monitoring purposes will be treated as confidential and it will not be used for any other purpose.

If monitoring shows that the Company, or areas within it, are not representative, or that sections of our workforce are not progressing properly within the Company, then an action plan will be developed to address these issues. This will include a review of recruitment and selection procedures, Company policies and practices as well as consideration of taking legal Positive Action.

Grievances/Discipline

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

Review

The effectiveness of this policy and associated arrangements will be reviewed annually under the direct supervision of the Business Owners.

Health and Safety Policy

Statement of General Policy

Navigate Eco Solutions Limited fully accepts the obligations placed upon it by the various Acts of Parliament covering health and safety. The Company requires its directors to ensure that the following policy is implemented and to report regularly on its effectiveness.

Management Organisation and Arrangements

This policy has been prepared and published under the requirements of Health & Safety at Work legislation. The purpose of the policy is to establish general standards for health and safety at work and to distribute responsibility for their achievement to all employees through the normal line management processes.

Management Responsibilities

Directors

The directors have overall responsibility for the implementation of the Company's policy. They are responsible for ensuring that the policy is widely communicated and that its effectiveness is monitored.

Safety Officer

The Safety Officer is a nominated manager responsible for co-ordinating effective health and safety policies and controls across the organisation.

The Safety Officer is responsible for:

The production and maintenance of the Company's policy and ensuring that Department Guidelines are consistent with policy
Its application
Monitoring and reporting on the effectiveness of the policy
The identification of health and safety training needs
The production and maintenance of any health and safety documents or codes of practice as necessary for any relevant area of the Company services where this is required

Health and Safety Management Process

Navigate Eco Solutions Limited believes that consideration of the health, safety and welfare of staff is an integral part of the management process. The provision of the Health and Safety at Work etc Act, associated Codes of Practice and other relevant Directives will be adopted as required standards within the Company. Responsibility for health and safety matters shall be explicitly stated in management job descriptions.

The Company requires all staff to approach health and safety in a systematic way, by identifying hazards and problems, planning improvements, taking executive action and monitoring results so that the majority of health and safety needs will be met from locally held budgets as part of day-to-day management, although many health and safety problems can be rectified at little additional cost.

For major additional expenditure, cases of need will be submitted to the directors.

If unpredictable health and safety issues arise during the year, the directors must assess the degree of risk, in deciding the necessary resources and actions to commit to addressing these issues.

Health, Safety and Welfare Guidelines

It is the policy of Navigate Eco Solutions Limited to require the Directors to produce appropriate health and safety policies or guidelines to all levels within the organisation. These should embody the minimum standards for health and safety for the department and the work organised within it.

It shall be the responsibility of the Directors to bring to the attention of all members of their staff, the provisions of the guidelines, and to consult with appropriate Health and Safety Representatives about the updating of these guidelines.

Identification of Health and Safety Hazards

Annual Audit and Regular Risk Assessments

It is the policy of Navigate Eco Solutions Limited to require a thorough examination of health and safety performance against established standards annually. The technique to be adopted for such examinations will be the 'Safety Audit'. The Audit requires review of:

standards laid down in the policy
relevant regulations
environmental factors
staff attitudes
staff instructions
methods of work
contingency plans
recording and provision of information about accidents and hazards and the assessment of risk

The information obtained by the Audit will be used to form the basis of the plan for the following year.

The responsibility for ensuring that audit activity is carried out as part of this policy rests with the Directors and will be carried out by the Safety Officer. Although the Audit remains a management responsibility, managers are required as part of this policy to seek the involvement of the appropriate Health and Safety Representative in the conduct of the Audit.

It is the management's responsibility to ensure that any deficiencies highlighted in the Audit are dealt with as speedily as possible. In addition to carrying out Safety Audits, it is the responsibility of the Directors to have checked, at least quarterly, all portable equipment, including electrical appliances, in their area, and to ensure that all problems are immediately dealt with.

Directors have a continual responsibility for the elimination of hazards in order to maintain a safe working environment and will also be expected to carry out regular risk assessments in line with the Health and Safety Executive Guidelines; that is follow the 5 steps:

Identify the hazards
Decide who might be harmed and how
Evaluate the Risks and decide on precautions
Record the findings and implement the precautions
Review the assessment and update when necessary

Safety Representatives

Navigate Eco Solutions Limited will support Safety Representatives in carrying out their role and give all reasonable assistance. Safety Representatives will be encouraged to discuss specific health and safety issues with the relevant Co-Founder. They may also formally report hazardous or unsafe circumstances to the Directors and will be formally notified of the remedial action taken or be given a reason why the action cannot be taken.

Records, Statistics and Monitoring

The Company will operate systems for recording, analysis and presentation of information about accidents, hazard situations and untoward occurrences. Advice on systems will be provided by the Safety Officer, in conjunction, where appropriate with specialist advisory bodies for example local Environmental Health Departments, and the responsibility for the operation of these systems rests with the Directors. Information obtained from the analysis of accident statistics must be acted upon.

The responsibility for meeting the requirements of the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1985 (RIDDOR) to the Health and Safety Executive, shall rest with the Directors.

The Occupational Health Service

It is the policy of the Company to obtain independent Occupational Health advice when required. Such services can include counselling on health and associated matters, investigation of hazards and accidents, environment studies, health interviews and employment medicals.

First Aid

It is the policy of the Company to make provision for First Aid and the training of 'First Aiders' in accordance with the First Aid Regulations (1982). The Safety Officer is responsible for ensuring the Regulations are implemented and for identifying training needs.

Fire

The Directors are responsible for ensuring that the staff receive adequate fire training, and that nominated fire officers are designated in all Navigate Eco Solutions Limited premises. Currently all staff work from home. Should Navigate Eco Solutions Limited acquire premises, they will adhere to the following guidelines.

In addition, the Company will nominate a Fire Officer (this may be the Safety Officer or someone external to the Company) who will:

report and advise on the standard of fire safety in the Company's premises and the standard of fire training of its staff
undertake overall responsibility for fire training
assist in the investigation of all fires in the Company's premises and to submit reports of such incidents

Condemnation and Disposal of Equipment

Procedures for the, condemnation and disposal of equipment are determined by the Directors. Anyone introducing new equipment should have such equipment checked initially by the Safety Officer.

Food Hygiene

Anyone who has responsibility for food acquisition, storage, processing and serving, and staff induction and hygiene training, are responsible for ensuring that these functions are undertaken to the necessary legal standards. Any suspected outbreak of food poisoning or other unexplained and possibly food related incidents must be reported to the Safety Officer.

Lifting and Handling

Directors are responsible for informing staff of safe lifting techniques. The Safety Officer will identify specific training needs and ensure training in lifting and handling is provided to staff who require it.

Non-Smoking on Company Premises

Navigate Eco Solutions Limited policy is that there will be no smoking in its buildings (when acquired). The overall aim is to reduce smoking and so save life, reduce risk of fire, prevent unnecessary illness and chronic disability. These rules also extend to e-cigarettes / vaping.

Control of Substances Hazardous to Health

The Control of Substances Hazardous to Health Regulations (COSHH) require the Company to identify those substances which are in use and which are hazardous to health (as legally defined) and to assess the risk of those substances. The Company must also provide and use controls to prevent exposure to substances hazardous to health; maintain controls by monitoring exposure, or by health surveillance of employees; and provide information, instruction, and training for employees on all these matters. The Safety Officer is responsible for implementing these Regulations.

Computer Installations and Visual Display Units

All new computer installations must adhere to the British Standard Specifications and comply with the Health and Safety (Display Screen Equipment) Regulations 1992. All new employees operating such equipment are expected to read the Health and Safety Executive guidance entitled 'Working with Display Screen Equipment'. New employees who regularly use VDUs will be required to undergo sight screening.

Control of Working Time

Navigate Eco Solutions Limited is committed to the principles of the Working Time Regulations. No member of staff is expected to work more than 48 hours per week (including overtime) unless there are exceptional circumstances.

Health and Safety and the Individual Employee

The Health and Safety at Work Act requires each employee 'to take reasonable care for the Health and Safety of himself and of other persons who may be affected by their acts and omissions' and co-operate with management to enable management to carry out their responsibilities under the Act. Employees have equal responsibility with the Company for Health and Safety at Work.

The refusal of any employee to meet their obligations will be regarded as a matter to be dealt with under the Disciplinary Procedure. In normal circumstances counselling of the employee should be sufficient. With a continuing problem, or where an employee leaves themself or other employees open to risk or injury, it may be necessary to implement the formal stages of the Disciplinary Procedure.

Modern Slavery Statement

Introduction

Modern slavery is a heinous crime and a morally reprehensible act that deprives a person's liberty and dignity for another person's gain. It is a real problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being involved in this crime through its own operations and its supply chain.

At Navigate Eco Solutions Ltd (Navigate) we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation and supply chain. We have taken concrete steps to tackle modern slavery, as outlined in our statement. This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking during the financial year 20/21.

Our business and supply chains

Navigate Eco Solutions Ltd is a provider of Information Technology products and services. Our supply chain has a technology focus and we operate solely in the UK.

We establish a relationship of trust and integrity with all our customers and suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the supplier's reputation, respect for the law, compliance with health, safety and environmental standards, and references.

Policies and Supplier Due Diligence

Navigate operates the following processes for identifying and preventing slavery and human trafficking in our operations:

Whistleblowing - we encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation.
Navigate encourages employees to do the right thing and behave professionally and do what is expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour.

We require all suppliers to attest that:

They do not use any form of forced, compulsory or slave labour
Their employees work voluntarily and are entitled to leave work
They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment
They do not require employees to post a deposit/bond and do not withhold their salaries for any reasons
They do not require employees to surrender their passports or work permits as a condition of employment

Last updated: 18th June 2024