This page outlines some of our key policies and values as a business. We have a lot more and are happy to share them. If you want to know more, please just ask.

These terms and conditions (the “Terms and Conditions”) govern the use of www.subfrantic.com (the “Site”). This Site is owned and operated by Subfrantic Ltd. This Site is a principally a portfolio.

By using this Site, you indicate that you have read and understand these Terms and Conditions and agree to abide by them at all times.

Effective Date: 1st day of May, 2024

The General Data Protection Regulation (GDPR) applies from 25 May 2018, when it supersedes the UK Data Protection Act 1998 (DPA). Significant and wide-reaching in scope, the new law brings a 21st century approach to data protection. It expands the rights of individuals to control how their personal data is collected and processed, and places a range of new obligations on organisations to be more accountable for data protection.

INTRODUCTION

This privacy policy tells you what will happen to any personal data that you provide to Subfrantic as a result of using this website, social media sites or contacting this company. We fully understand that your privacy is important to you and that you care about how your personal data is used and shared and we will take account of, and respect, your concerns.

This policy explains how we will use, and protect, the information that we gather, whether it be through this website, social media sites, by way of telephone, email, or personal conversations or through our normal business contacts with you. Please read this privacy policy carefully and ensure that you understand it. By visiting our websites, accessing one of our social media pages and/or using our services, you are accepting to the practices described in this policy.

The data controller is Subfrantic Limited, a company incorporated in England and Wales under the company number 9277274

Registered address:

Unit 5 Holmshaw Farm,

Layhams Road

Bromley

BR2 6AR

Tel: +44(0)20 8066 5015

WHAT PERSONAL DATA DO WE COLLECT?

Personal data that we may collect, use, store and share (when appropriate) about you includes, but is not restricted to:

Identity Data such as names, usernames or similar; marital status; title; date of birth; sex and gender.

Contact Data such as addresses; email addresses and telephone numbers.

Financial Data such as bank account and payment card information.

Transaction Data such as information about payments and details of purchases you have made.

Technical Data such as IP addresses; login data; browser info; time zone; location; browser plug-ins; operating systems; platforms and other technology on the device used to access this website.

Profile Data such as usernames; passwords; security answers; purchases/orders; interests; preferences; feedback and responses to surveys, blogs and messages.

Usage Data such as analytics relating to how you use the website.

Marketing and Communications Data such as your preferences about receiving communications from us or third parties.

Special Categories of Data such as details about race or ethnic origins, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic or biometric data.

We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data can be derived from your Personal Data but is not itself Personal Data as it cannot be used to reveal your identity. If Aggregated Data is ever used in combination with your Personal Data and becomes identifiable, it will be treated in accordance with this notice.

Subfrantic does not collect any Special Categories of Personal Data about you or any information about criminal convictions/offences.

EXAMPLES OF THIS ARE:

If you are a customer of Subfrantic:

• your first and last name
• email address, postal address, telephone number
• details of the transactions which you conduct using our services

If you are a job applicant, employee or contractor:

• your full name, contact details (including address, phone number and email address)
•  identification details
• job title
• employment history
• education details
• names and contact details of referees
• next of kin details
• national insurance number
• other information if required by law

OTHER CONTACT WITH SUBFRANTIC

• personal data that you provide by completing forms on the Websites, including if you sign up to receive our emails 
• attend one of training events
• use one of our services
• request any information
• enter into any competition or promotion
• if you register or create an account with us, your log-in and password details
• information contained in messages when you post on our social media pages
• information contained in communications you send to us

You are under no obligation to provide any such data. However, if you choose to withhold requested information, you may not be able to access all of the website’s content and our services.

SOCIAL MEDIA PLATFORMS

Communication, engagement and actions taken through external social media platforms that we participate on are subject to the terms and conditions as well as the privacy policies of those social media platforms.

You are advised to use social media platforms wisely and communicate/participate on them with due care and caution with regard to your personal data. We will never ask for personal or sensitive data through social media platforms and we encourage users wishing to discuss sensitive details to contact the relevant platform provider through primary communication channels such as by telephone or email.

These websites may use social sharing buttons which help share web content directly from our web pages to the social media platform in question. Where you use such social sharing buttons you do so at your own discretion – you should note that the social media platform may track and save your request to share a web page respectively through your social media platform account. Please note these social media platforms have their own privacy policies, and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these social media platforms.

SHORTENED LINKS IN SOCIAL MEDIA

We may through our social media platform accounts share web links to relevant web pages. By default some social media platforms shorten lengthy URLs. 

Users are advised to take caution and exercise good judgement before clicking on any shortened URLs published on social media platforms by us. Despite the best efforts to ensure only genuine URLs are published, many social media platforms are prone to spam and hacking and therefore we cannot be held liable for any damages or implications caused by visiting any shortened links.

WHY WE USE THIS DATA? (OUR LAWFUL BASIS FOR USING THIS DATA)

We only collect and use personal information about you when the law allows us to. Most commonly, we use it where we need to:

• Fulfill a contract we have entered into with you
• Comply with a legal obligation

Less commonly, we may also use personal information about you where:

• You have given us consent to use it in a certain way
• We need to protect your vital interests (or someone else’s interests)
• We have legitimate interests in processing the data

WHAT ARE SUBFRANTIC’S LEGITIMATE INTERESTS?

Legitimate interests are a flexible basis upon which the law permits the processing of an individual’s personal data. To determine whether we have a legitimate interest in processing your data, we balance the needs and benefits to us against the risks and benefits for you of us processing your data. This balancing is performed as objectively as possible by our Data Protection Lead. You are able to object to our processing and we shall consider the extent to which this affects whether we have a legitimate interest.

STAFF RESPONSIBILITIES

All staff are responsible for:

• checking that any information that they provide to Subfrantic in connection with their employment is accurate an up to date.
• Informing Subfrantic of any changes to information that they have provided, e.g. Changes of address, either at the time of appointment or subsequently – Subfrantic cannot be held responsible for any errors unless the employee has informed of such changes.

SUBJECT CONSENT

Consent is one lawful basis for processing, and consent (or explicit consent) can also legitimise use of special category (sensitive) data, restricted processing and overseas transfers of data.

Subject consent will have to be explicit, in relation to each processing activity, and freely given. Consent will not be freely given if there is imbalance in the relationship between the individual and the data controller — this will make consent particularly difficult for employers, who should look for an alternative lawful basis where possible.

Employers will not be able to rely on a generic reference to consent within an employment contract or data protection policy, which an employee is required to agree as part of wider terms and conditions. Consent must be capable of being easily withdrawn by the employee at any time, This means employers need to have simple and effective withdrawal mechanisms in place.

Where relying on consent to process personal data, being able to prove how consent was obtained will be vital for employer compliance with the GDPR.

HOW WE RETAIN YOUR INFORMATION

We retain personal data relating to payments, VAT, tax and accounts for the minimum statutory periods required by UK law.

Unless stated separately under the headings of various Data Subjects, we retain information relating to purchases, rentals, installations and other services we offer to enable us to perform those services in a professional manner. For example, to service equipment, offer software upgrades, or fulfill contracts we will retain your information for the time necessary to fulfill these requirements. We also use historical information to analyse the performance of the business over time and plan for the future success of the company. We only keep this information for as long as is necessary to perform these tasks.

HOW DO WE SHARE YOUR INFORMATION?

We will not sell, trade transmit or otherwise pass on your personal information to a third party, except where it is necessary to deliver our services. In such cases, we may share your personal information with business partners, suppliers and sub-contractors for the performance of any contract we enter into with (them or) you, including without limitation any data processor we engage.

HOW DO WE PROTECT PERSONAL DATA?

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect personal data relating to you, we cannot guarantee the security of such data transmitted to the Websites; any transmission is at your own risk. Once we have received personal data relating to you, we use strict procedures and security features to try to prevent unauthorised access.

RIGHT TO DATA PORTABILITY

Subfrantic recognises that, under the GDPR, you must be able to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability. The requested information will be provided free of charge in a structured, commonly used and machine-readable form. However, it should be noted that the right to data portability only applies:

• to personal data an individual has provided to a controller
• where the processing is based on the individual’s consent or for the performance of a contract
• When processing is carried out by automated means

DATA BREACHES

While we will take all appropriate measures to prevent illegal access to your data, we have to prepare for that possibility. Should there be a significant data breach affecting your data and rights, we will notify you (and the ICO) as soon as possible. To minimise any possible danger, we will use encryption and/or pseudonymisation where it is appropriate to do so. We will also have backup systems in place in the event that an outside organisation attempts to disrupt access to our data,

COOKIES

A cookie is a small text file placed on your computer or device by our site when you visit certain parts of it and/or use certain of its features. For example, we may monitor how many times you visit, which pages you go to, traffic data, location data, weblogs and other communication data whether required for billing purposes or otherwise. We may also look at the originating domain name of a user’s internet service provider, IP address, operating system and browser type. This information helps us to build a profile of our users. Where appropriate, this data will be aggregated or statistical, which means that we will not be able to identify you individually.

Cookies are also used to remember your settings (language preference, for example) and for authentication (so that you do not have to repeatedly sign in). You can set your browser not to accept cookies and there are a number of websites which explain how to remove cookies from your browser. However, it is possible that some of our website features may not function as a result.

CHANGES TO OUR PRIVACY POLICY

We keep our privacy policy under regular review and we will place updates on this web page. Please see the top of this page for when this was last updated.

COMPLAINTS

We take any complaints about our collection and use of personal information very seriously.

If you think that our collection or use of personal information is unfair, misleading or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance by emailing [email protected]

CONTACTING US

If there are any questions regarding this privacy policy, you may contact us using the information below.

Subfrantic Production Services Ltd

Unit 5, Holmshaw Farm

Layhams Road

Bromley

BR2 6AR

Tel: +44(0)20 8066 5015

POLICY STATEMENT

Subfrantic Production Services Ltd is an equal opportunities employer and is committed to equality of opportunity, diversity and to providing a service and following practices which are free from unfair and unlawful discrimination.

It is this company’s policy to treat all job applicants and employees fairly and equally, regardless of sex, pregnancy, trans-gender status, sexual orientation, religion or belief, marital status, civil partnership status, age, race, colour, nationality, national or ethnic origins or disability. Subfrantic will monitor the composition of the workforce to ensure that this policy is effective.

Equality of opportunity, valuing diversity and compliance with the law is to the benefit of all individuals in our company as it seeks to develop the skills and abilities of its people. While specific responsibility for eliminating discrimination and providing equality of opportunity lies with managers and supervisors, individuals at all levels have a responsibility to treat others with dignity and respect. The personal commitment of every employee to this policy and application of its principles are essential to eliminate discrimination and provide equality throughout Subfrantic.

Through this policy and procedure and the training and development of managers and staff, the company will do all it can to promote good practice in this area in order to eliminate discrimination and harassment as far as is reasonably possible. Subfrantic will also continue to work towards its dedicated goal of encouraging and promoting equality and diversity within the workforce.

The Managing Director has particular responsibility for implementing and monitoring this policy, as part of this process, all personnel policies and procedures are administered with the objective of promoting equality of opportunity, diversity and eliminating unfair or unlawful discrimination.

PROCEDURE

1. Subfrantic aims to provide services to which all clients/customers are entitled regardless of age, disability, gender reassignment, marriage and civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation, offending past, caring responsibilities or social class. We will make sure that our services are delivered equally and meet the diverse needs of our service users and clients by assessing and meeting the diverse needs of our clients.
2. Subfrantic is an equal opportunity employer. Equal opportunity is about good employment practices and efficient use of our most valuable asset, our employees. Every manager and employee has personal responsibility for the implementation of the policy. Any instance of doubt about the application of the policy, or other questions, should be addressed to your line manager, as should any requests for special training.
3. The company will not discriminate on grounds of sex, trans-gender status, pregnancy or maternity, sexual orientation, religion or beliefs, marital status, civil partnership status, race, ethnic origin, colour, nationality, national origins, disability or age, or any other grounds (whether prohibited by legislation or otherwise).
4. The non-discrimination principle inherent in this policy includes the prohibition of discrimination against an individual because they associate with someone of a particular race, religion, sexual orientation, age, etc, for example an employee who is married to someone of a minority ethnic origin or who socialises with gay or lesbian friends.
5. The prohibition on discrimination applies equally to situations where someone thinks or perceives (whether rightly or wrongly) that a colleague is of a particular race, sexual orientation, religion, age, sex or that they have a disability, is a trans-gender person, or is pregnant.
6. The policy applies to the process of recruitment and selection, promotion, training, conditions of work, pay and benefits and to every other aspect of employment, including general treatment at work and the processes involved in the termination of employment.
7. 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 company.
8. Where increased pay and/or enhanced benefits are offered to employees on the basis of length of service, these are intended to reward loyalty, maintain motivation and reflect higher levels of relevant experience.
9. The policy applies to job applicants (both internal and external) and all employees and other workers whether full time, part time, temporary, seasonal or contract.
10. Employees should note that the imposition of any provision, criterion or practice which has a disproportionate adverse impact on someone for a reason related to sex, transgender status, race, married status, civil partnership status, religion or belief, sexual orientation, disability or age will be unlawful unless it can be objectively justified. In the event of any query or doubt, your line manager should be consulted.
11. When establishing criteria for recruitment and promotion into vacant posts, the company will consider carefully whether any minimum or maximum number of years of relevant experience is necessary for effective performance of the job. Such restrictions will not be imposed unless there is a proper job-based reason why they are necessary.
12. Subfrantic recognises the dangers of unconscious bias arising at work, which is where an opinion is formed on an individual by a manager or colleague without them necessarily being aware they have formed it. There are many different forms of unconscious bias, ranging from an affinity towards those of a similar background to placing too much significance on what has been identified as a negative trait.
13. Subfrantic works against forms of unconscious bias in all decisions taken for employment, including recruitment, promotion and training opportunities, with a focus on promoting diversity and inclusion.
14. The company does not operate any compulsory retirement age, and each employee may choose for him/herself when to stop working, subject to them continuing to be sufficiently fit to perform their job to a satisfactory standard.
15. Subfrantic will, whenever it is operationally possible to do so, agree to any request from an employee who is aged 63 or over and who has indicated an intention to retire within the following two years to reduce their hours of work with a view to a phased retirement. The precise reduction to the number of days or hours worked will be discussed individually in each case.
16. Employees who are disabled or become disabled in the course of their employment should inform the company about their disability. Management will then arrange to discuss with the employee what reasonable adjustments to their job or working conditions or environment might assist them in the performance of their duties. The employee will also be encouraged to suggest any adjustments that they believe would be helpful. Careful consideration will be given to any proposals and, where reasonable and reasonably practicable, such adjustments will be made. There may, however, be circumstances where it will not be reasonable or reasonably practicable for Subfrantic to accommodate proposals put forward by the employee.
17. Any member of staff may use the Subfrantic Grievances Policy to complain about discriminatory conduct. If the matter relates to sexual or racial harassment or harassment on the basis of disability, sexual orientation, trans-gender status, religion or belief or age, then the complaint may be raised directly with your line manager. The company is concerned to ensure that staff feel comfortable about raising such complaints. No individual will be penalised for raising such a complaint unless the substance of the complaint is untrue or the complaint is made in bad faith, for example out of malice.
18. Where an employee is falsely accused of discriminatory conduct, then they may implement the company’s care service’s grievance procedure.
19. Any employee who makes a false accusation of harassment will be subjected to disciplinary action. In serious cases, such behaviour may be deemed to constitute gross misconduct and may result in summary dismissal.
20. All employees and job applicants will be asked, on a purely voluntary basis, to complete a form denoting their sex, race, ethnic origin, age and any disabilities that they have. Subfrantic’s care service guarantees that the information provided on this form will be used solely for the purpose of monitoring the effectiveness of its equal opportunities policy.
21. This policy will be monitored on a regular basis by senior management. Where there are issues with the way the policy is working, these will be looked at closely with a view to identifying measures to improve the effectiveness of the policy.

POLICY STATEMENT

Subfrantic Production Services Ltd’s approach to bullying and harassment is one of zero tolerance. Any instance of bullying or harassment or other inappropriate behaviour at work that is likely to cause offence or breach the dignity and respect of colleagues will be regarded as serious misconduct. Employees responsible for such behaviour will be subject to disciplinary action, up to and including summary dismissal, depending on the nature and seriousness of the behaviour.

PROCEDURE

• EMPLOYEES

1. All workers and employees have a responsibility at all times to behave in a way that is courteous, respectful and reasonable towards their colleagues.
2. Swearing and using other offensive terms during the course of employment will be viewed as a disciplinary offence. Similarly, the telling of jokes, engagement in banter or making remarks that could reasonably cause offence to any person, including anything that is sexual in nature, sexist, racial, racist, homophobic, ageist, connected to religion or belief, or related to an individual’s disability will also be viewed as a disciplinary offence, potentially leading to disciplinary action up to and including summary dismissal.
3. This policy also applies to organised work-related events regardless of the fact that these may be held outside the companies premises and in employees’ own time.
4. All complaints from employees under this policy will be treated seriously and investigated and dealt with promptly, fairly and objectively and, insofar as is possible, in confidence.
5. No employee will be penalised, victimised or subjected to any detriment for complaining that his or her dignity has been breached through a colleague’s words or actions.
6. If at any time there are grounds to believe that an employee has bullied, harassed or otherwise caused offence to another employee, the company will instigate an investigation into the alleged behaviour. This will be the case whether or not there has been a formal complaint.
7. In these circumstances, Subfrantic reserves the right to suspend temporarily or re-deploy either the employee suspected of acting in breach of this policy, or the employee who has made a complaint of bullying or harassment, if it is considered in the interests of the individual(s) or the company to do so. Suspension in these circumstances will be on full pay. Suspension does not mean that the employee has been found guilty of misconduct and does not constitute disciplinary action.
8. Any employee who believes that their dignity has been violated or that another employee’s conduct amounts to bullying or harassment or that such conduct has otherwise created an uncomfortable environment for themselves or others, has the right to complain to their line manager. Such a complaint may be informal or formal, as the employee thinks appropriate (see below).
9. Furthermore, any employee who witnesses an incident that may reasonably be viewed as offensive is obliged to report in factual terms what they saw or heard to their line manager so that Subfrantic can investigate and resolve the matter.
10. If an employee wishes to make an informal complaint, they may choose either to speak:
    1. directly to the person whose behaviour has caused, or is likely to cause, offence, pointing out to that person in a reasonable and factual way why their conduct may be inappropriate, why it may be perceived as objectionable or unacceptable, and asking for it to stop
    2. to their line manager in order to seek support or guidance on an appropriate course of informal action to resolve the matter.
11. If an employee’s behaviour is such that it represents a serious breach of Subfrantics’s dignity policy (for example severe bullying or harassment), or if the employee has tried to resolve the matter informally but without success, the employee may choose to raise a formal complaint.
12. A formal complaint must be put in writing, although the employee may consult their line manager first to ask for guidance on how to present the written complaint.

• MANAGERS

As soon as a manager becomes aware that an employee’s conduct or behaviour may be in breach of this policy, or as soon as a complaint (whether formal or informal) is received, the manager will take the following action.

1. Consider whether it would be appropriate to suspend or temporarily re-deploy the employee suspected of acting in breach of this policy (and/or the employee who made the complaint) to allow the investigation to proceed without impediment.
2. Talk informally and in confidence with the employee who made the complaint to establish all his or her evidence, including specific examples of the words and actions of the other employee. During the course of such a meeting, the employee will be asked to disclose:
   1. the name of the person alleged to have committed a breach of this policy
   2. what specifically the employee personally observed, including the words said, tone of voice, manner and surrounding circumstances, as far as the employee can remember
   3. the times and dates of any alleged incidents
   4. the names of anyone else who was present.
3. Seek if possible to obtain written statements from any such employees.
4. Write to the employee who is alleged to have acted in breach of this policy, setting out the details of the complaint against him or her and inviting him or her to attend an investigative meeting.
5. Allow the employee the right to be accompanied to the meeting by a work colleague or trade union official.
6. At the interview, allow the employee a full and fair opportunity to answer the allegations and to put forward his or her version of events.
7. Assess objectively and fairly whether the employee’s conduct appears to have amounted to bullying or harassment or otherwise to an infringement of this policy.
8. Decide, in conjunction with the HR manager or department, what action to take. This may include informal counselling, discussions with both parties with a view to conciliation, or disciplinary action.
9. Communicate the decision both to the employee who made the complaint and to the employee accused of breaching the policy as soon as possible following the conclusion of this procedure.
10. If disciplinary action is taken, allow the employee the right to appeal against the disciplinary decision.
11. Keep records of the investigation and all meetings held and ensure these are treated as confidential and in accordance with the relevant provisions of the Data Protection Act 2018.

POLICY STATEMENT

Subfrantic Production Services Ltd recognises that environmental concerns are becoming increasingly important in society and that businesses have both a legal and an ethical duty to ensure that they behave in an environmentally sensitive and acceptable way.

Subfrantic is committed to improving upon its environmental performance by complying with relevant guidance and regulation and by adopting modern methods of environmental management and sustainable development wherever practicable.

The aim of this policy is to enable Subfrantic to:

1. reduce its impact on the environment
2. ensure compliance with environmental legislation and regulations
3. ensure the effectiveness of its environmental management systems
4. reduce its use of energy and resources
5. minimise its waste
6. reduce unforeseen environmental risks.

DEFINITION OF SUSTAINABLE DEVELOPMENT

This company understands “sustainable development” to refer to an approach to development where the needs of present businesses and societies are met without compromising the ability of future generations to meet their own needs. Most importantly, this includes the effective protection of the environment and the prudent use of natural resources.

Waste Management and Recycling

All organisations produce waste and are increasingly required to ensure that they deal with that waste in an environmentally acceptable way that is compliant with the law.

The vast majority of household, commercial and industrial waste is disposed of to landfill and all waste disposal activities at landfill sites are tightly regulated by a waste management licensing system in force under the Environmental Protection Act 1990.

Government sustainability policy is to reduce the percentage of waste being disposed of in landfill year on year by increasing the reusing of items, increasing the composting of organic waste and by increasing and developing recycling schemes.

In this business, all:

1. waste will be segregated into appropriate waste streams prior to disposal
2. waste appropriate for recycling (ie plastics, paper, tins and glass) will be placed in the appropriate receptacles ready for collection by recycling services
3. other domestic waste will be placed inside black waste bags

electrical waste will be disposed of according to the Waste Electrical and Electronic Equipment (WEEE) Regulations

1. discarded furniture and office equipment will be offered to charity for recycling or reuse.

Subfrantic intends to comply with all current national and local waste management laws, policies and procedures. Thecompany will liaise regularly with the appropriate local authority department to regularly review its performance in this area.

ENERGY EFFICIENCY

Energy for lighting, heating and ventilation is expensive and conserving or making best use of energy is not only good for the environment but also saves money as well.

To conserve power, staff should:

1. turn off non-essential lights and power sources when not in use
2. keep windows and doors closed when using heating
3. report malfunctioning thermostats on radiators immediately.

In addition, the company will invest in energy efficient buildings by:

1. installing and running energy efficient boilers and heating systems
2. ensuring that boilers and heating systems are regularly serviced and properly maintained
3. ensuring that energy efficient light bulbs and low power or energy efficient equipment are used wherever possible
4. ensuring that all buildings, pipes and lofts are properly insulated and maintained

WATER WASTAGE

Water is also an expensive resource that should not be wasted. Staff should ensure that they only use as much water as is necessary. They should report any dripping taps or leaking pipes immediately.

SUSTAINABLE PROCUREMENT

Subfrantic will endeavour to ensure that all resources, goods and services are only bought or contracted from organisations and companies who have sustainable use policies in place. Those staff responsible for purchasing should ensure that suppliers use environmentally acceptable packaging.

POLLUTION

Pollution will be minimised by:

1. investing in cleaner equipment and processes wherever practicable
2. ensuring that existing equipment is maintained and serviced
3. ensuring that any dangerous substances are used and disposed of properly.

TRANSPORT

Transport is a major source of carbon emissions, of fuel use and of pollution worldwide. In this company, the environmental impact of transport used will be minimised by:

1. ensuring that all vehicles and transports operated by Subfrantic are serviced regularly and are kept in good condition, thus, enabling them to run efficiently
2. eliminating the use of vehicles for unnecessary trips
3. encouraging and facilitating vehicle sharing where possible
4. moving to low-emission vehicle use wherever possible
5. supporting staff use of public transport, cycling and walking to travel to and from work.

NOTES ON USING THIS POLICY

Section 54 of the Modern Slavery Act 2015 applies to all commercial organisations which carry on business or part of a business in the UK and have a turnover of £36 million or more per annum. Section 54 can therefore apply to non-UK registered companies.

INTRODUCTION

This policy ensures that Subfrantic Production Services Ltd complies with s.54 of the Modern Slavery Act 2015, and sets out the responsibilities for employers and employees.

Subfrantic is committed to ensuring that all of its business operations are free from involvement with slavery or human trafficking.

UPDATED STATEMENT

When appropriate, Subfrantic will publish an updated slavery and human trafficking statement. A link to this statement will be on the Small Print page of the website and will be approved by the Managing Director.

CONTENT OF THE STATEMENT

The following items will be included in the statement.

1. The structure of our company, the business operations of Subfrantic and the supply chains.
2. Our policies in relation to slavery and human trafficking.
3. The due diligence processes that we carry out to ensure that there is no slavery or human trafficking in our business and supply chains.
4. Identification of any parts of our business and supply chains where there is a risk of slavery or human trafficking take place, and the steps that we have taken to assess and manage the risk.
5. An assessment of the effectiveness of the measures that we have taken to stop slavery and human trafficking taking place, and the way that we assess and manage the risks that are identified.
6. A statement that training about slavery and human trafficking is available to all employees.

ADDITIONAL ACTION PLANS

In addition to producing the annual statement, Subfrantic is committed to:

• ensuring that slavery and human trafficking is considered and addressed in our approach to corporate social responsibility
• ensuring that any concerns about slavery or human trafficking can be raised through our whistle blowing procedure
• carrying out regular audits to ensure that all our employees are paid at least the National Minimum Wage and have the right to work in the UK
• ensuring that all commercial agreements include an obligation on our suppliers to operate in accordance with the Modern Slavery Act 2015, and to ensure that any of their suppliers and sub-contractors also operate in accordance with the Act
• appointing a named individual to oversee the compliance with the Modern Slavery Act 2015 this person is Stephen Davies
• identifying and addressing any areas of high risk in our supply chain
• providing training for all employees who are involved in the supply chain on issues relating to slavery and human trafficking.

GENERAL STATEMENT

Subfrantic Production Services Ltd is committed to ensuring the health, safety and welfare of its employees, so far as is reasonably practicable. We also fully accept our responsibility for others who may be affected by our activities, such as contractors, visitors and members of the public. We will take steps to ensure that our statutory duties are met at all times.

Each employee will be given such information, instruction and training as is necessary to ensure that they can carry out their work tasks safely.

It is the duty of management to ensure that all processes and systems of work are designed to take account of health and safety and are properly supervised at all times.

Adequate facilities and arrangements will be maintained to enable employees and their representatives to raise issues of health and safety.

Competent people will be appointed to assist us in meeting our statutory duties including, where appropriate, specialists from outside Subfrantic.

Every employee must co-operate with us to enable all statutory duties to be complied with. The successful implementation of this policy requires total commitment from all levels of employee, from the Directors to freelancers. Each individual has a legal obligation to take reasonable care for their own health and safety, and for the safety of other people who may be affected by their acts or omissions. Full details of Subfrantic’s arrangements for health and safety will be set out in separate documents.

This policy will be regularly monitored to ensure that the objectives are achieved. It will be reviewed and, if necessary, revised in the light of any legislative or organisational changes.

ORGANISATIONAL ARRANGEMENTS

In order to ensure that health and safety is successfully managed within the company, the following responsibilities have been allocated.

OVERALL RESPONSIBILITY

Managing Director accepts overall responsibility for all matters, including those regarding health, safety and welfare.

ORGANISATIONAL RESPONSIBILITY

Subfrantic commits to:

• establish and implement a health and safety management system to manage the risk associated with our premises and activities
• regularly monitor our performance and revise our health and safety management system as necessary, to ensure we achieve our objective of continuous improvement
• provide sufficient resources to meet the requirements of current health and safety legislation, and aim to achieve the standards of good practice applicable to our activities
• actively promote an open attitude to health and safety issues, encouraging staff to identify and report hazards so that we can all contribute to creating and maintaining a safe working environment
• communicate and consult with our staff on all issues affecting their health and safety and, in doing so, bring this policy to their attention
• provide adequate training for our staff to enable them to work safely and effectively, and to ensure they are competent and confident in the work they carry out
• carry out and regularly review risk assessments to identify hazards and existing control measures; we will prioritise, plan and complete any corrective actions required to reduce risk to an acceptable level
• maintain our premises and work equipment to a standard that ensures that risks are effectively managed
• ensure that responsibilities for health and safety are allocated, understood, monitored and fulfilled
• provide health surveillance for staff where appropriate, and maintain records
• co-operate with other organisations in these premises to ensure that they are aware of any risks to their staff and other people posed by our activities, that we are aware of any risks to our staff from their activities, and that we comply with the relevant requirements of fire legislation.

MANAGEMENT RESPONSIBILITY

Managers are responsible for ensuring that the safety policy is implemented within their own departments. Managers must monitor the workplace to ensure that safe conditions are maintained. Where risks are identified the manager must ensure that these are rectified, so far as is reasonably practicable.

Management duties include the following.

• Ensuring that employees, contractors and visitors are aware of safety procedures.
• Establishing that all equipment, plant and substances used are suitable for the task and are kept in good working condition; this includes the regular maintenance and servicing of equipment.
• Providing adequate training, information, instruction and supervision to ensure that work is conducted safely.
• Taking immediate and appropriate steps to investigate and rectify any risks to health and safety arising from the work activity.
• Bringing to the prompt attention of Managing Director any health and safety issue that requires their attention.
• Ensuring that all accidents and “near misses” are properly recorded and reported and that an investigation is carried out to determine causal factors.
• Maintaining safe access to and egress from the workplace at all times.

Managers dealing with particular topic areas will be advised of any specific health and safety duties. (For example, the purchasing manager will be required to obtain material safety data sheets for COSHH purposes prior to ordering a substance for the first time.)

EMPLOYEE RESPONSIBILITY

All employees must:

• take reasonable care for their own health and safety
• consider the safety of other persons who may be affected by their acts or omissions
• work in accordance with information and training provided
• refrain from intentionally misusing or recklessly interfering with anything that has been provided for health and safety reasons
• report any hazardous defects in plant and equipment, or shortcomings in the existing safety arrangements, to a responsible person without delay
• not undertake any task they are not trained or authorised to do.
• Take responsibility for providing and maintaining their own PPE, when working on a Freelance basis.

HEALTH & SAFETY ASSISTANCE

Competent persons have been appointed to assist us in meeting our health and safety obligations. These people have sufficient knowledge and information to ensure that statutory provisions are met and that the safety policy is being adhered to.

Names, job titles and functions of these people are listed below.

Subfrantic recognises that there may be occasions when specialist advice is necessary. In these circumstances, the services of competent external advisors will be obtained.

First aid Subfrantic will maintain suitable numbers of first-aid personnel to deal with minor accidents and emergencies at the workplace. These personnel will have sufficient training and qualifications in accordance with statutory requirements. Identities of first aiders will be displayed throughout the workplace.

Emergency procedures are designed to give warning of imminent danger and to allow personnel to move to a place of safety. The manager of each department is responsible for ensuring that all employees and visitors within the area are informed of, and are fully conversant with, emergency procedures.

Fire marshals will be appointed for each area to assist with an evacuation. They will be given adequate instruction and training to ensure effectiveness.

Health surveillance — We will ensure that health surveillance of individuals is provided where required under statutory provisions or where this would be of benefit to maintaining health, safety and welfare.

Information and communication — We will ensure that suitable and relevant information relating to health, safety and welfare at the workplace is disseminated to staff and non-employees.

Statutory notices will be displayed throughout the workplace.

Safety committee meetings will be held regularly, during which time matters arising in connection with health and safety will be discussed.