Our Policies
- Mission Statement
- Drugs & Alcohol
- HSQE Policy
- Travel Time
- Work Safe
- Just Culture
- Sustainability
- Control of Bribery
- Equality & Dignity
- Modern Slavery
- Carbon Reduction Plan
- Corporate Social Responsibility
- Fatigue Management
Document Ref: OSL/ IMS/ POL/ 006
OSL’s Mission is to be the Delivery Partner of Choice.
Our intent is to deliver safe and efficient engineering projects and to drive continual improvement across the delivery and support groups within OSL, in order to achieve industry recognition as a collaborative partner delivering long-term benefits to our customers, business and delivery partners, and employees
OSL will continue to build upon our successes as a Unique Service Provider, involving multi-disciplinary Railway Engineering design, Construction and Testing & Commissioning activities, and to maintain Key Supplier status through key relationship management and supplier accreditations.
This mission statement will drive all aspects of our business, and inform our Business Strategy Action Plan, which is managed and monitored by OSL’s Delivery and Performance scorecard.
In simple terms we at OSL believe that ‘Good Business and Safety Performance Go Hand in Hand’.
Principal OSL Goals and Targets for 2022/2023:
Safety
OSL will Continue and further develop a blame free HSQE culture, recognising and embracing industry safe working mandates and engaging with Infrastructure Owners, our clients, and sub-contractor partners in the assurance and development of safe systems of work.
OSL strive for a zero Accident Frequency Rate with no loss time accidents to our personnel or contractors.
The business will record, review and learn from data in Close Calls, and reports of hazards, personal safety and technical incidents and engage with industry client’s and partners to identify and act upon all lessons learnt.
The Senior Leadership Team, Line Managers and the HSQE Team will engage with our on-site delivery teams to undertake site and office-based Surveillance and Safety Tours, and to encourage open dialogue and discussion with all staff.
Performance and Delivery
OSL embrace the industry objectives of ‘Putting Passengers First’, and recognise that Safe and Timely delivery of Engineering projects is paramount.
This will be further improved by close liaison with our clients, Infrastructure Owners, and our supply chain partners, including regular monitoring of project status, readiness
reviews, proactive and collaborative meetings to enable efficient resolution of key issues and maintain the progress of delivery.
OSL will ensure that the potential for critical system failures, unsafe or reportable events, and potential impact on the operational railway are avoided at all times.
We will work collaboratively with clients and delivery partners to identify, share and deliver whole life solutions, exploring innovative and efficient working practices, to support the entire Railway System
Regular monitoring and review of Employee, Supply Chain partner and Client feedback will be integral to OSLs approach to continuous improvement.
Sustainability
OSL embrace Industry Environmental Policies and Strategies and play an active role in the development of industry initiatives to reduce the impact of the business on the environment.
In line with Industry objectives, OSL set and monitor Science based Targets in order to avoid duplication and waste.
Resources
OSL encourage equality, diversity and inclusion in the workplace, recognising the benefits that a Diverse workforce can have, this is sound business practice
OSL create and maintain a working environment free of bullying, harassment, victimisation and unlawful discrimination, promoting dignity and respect for all, and celebrate individual differences and the contributions of all staff are recognised.
OSL will continue to further develop the Occupational Health and Wellbeing Policies and Procedures for our workforce to identify possible health matters at early stages, and to provide welfare and health support to all staff
OSL are committed to providing a healthy environment which employees and supply chain partners want to work in through proactive management of Fatigue, and the establishment of Mental Health First Aid team to help support the staff with the many challenges modern life, and the work environment may create
OSL will invest in all employees through delivery of relevant and high-quality training and will ensure high standards of engineering and delivery capability through the robust application of the OSL Competence Management System, which includes internal and external assessment processes, including the IRSE Licensing Scheme, external qualifications, and key Sentinel Scheme competencies.
OSL believe success emanates from the success of its staff and supply chain partners and manages this through an active employee competence management approach which
includes an in depth knowledge and assessment of both Technical and Non-technical skill sets.
OSL will provide all staff with the correct tools and equipment to carry out activities to high quality safety standards required when operating in a Safety Critical environment.
OSL see their success driven by Staff competence and capability and is actively involved in individual and team growth to meets todays’ and tomorrows challenges in the Rail environment, and recognises the key contribution we can make to the development, growth and recognition Engineering has in tomorrow’s world, we are and active advocate in STEM activities and a founding member of Cheshire Easts UTC programme to help inspire the next generation of engineers to aspire and inspire others
Document Ref: OSL/IMS/POL/002/23
OSL will ensure that its employees and contractors are made aware of the requirements of this Drugs & Alcohol Policy and will provide adequate resources to comply with the Transport and Works Act 1992, Misuse of Drugs Act, Network Rail Standard – NR/L2/OHS/00120 Drugs, Alcohol and Substance Abuse in the Workplace and Transport for London Company Policy for testing for Drugs & Alcohol.
OSL will always comply with Network Rail’s Drugs and Alcohol Policy and Client expectations as a minimum.
OSL operate a zero-tolerance policy for any individual being under the influence of drugs at work (other than prescribed levels of medication or over the counter medication, subject to certain safeguards) and being unfit through alcohol consumption.
It is a requirement of OSL that no employee or contractor shall:
- Report or endeavor to report for duty under the influence of drugs, medication or having just consumed alcohol.
- Prescribed or over the counter medication are reported to the employee’s line manager prior to reporting for duty / work.
- The above Line Managers contact the HSQE Team to arrange for approval / consultation with the OSL occupational health provider.
- Report for duty in an unfit state due to the use of drugs or alcohol
- Be in possession of illegal drugs in the workplace
- Consume illegal drugs or alcohol whilst on duty.
OSL will not tolerate any departure from this policy and will take the appropriate disciplinary action in the event of any infringement in accordance with the OSL Disciplinary Procedure.
A programme of screening has been put in place to:
- Detect the use of drugs or alcohol prior to employment / appointment
- Detect the use of drugs or alcohol of existing employees and contractors using random screening ensuring that 20% of the work force as a minimum is tested between 1st April to the 31st of January each year.
- Detect the use of drugs or alcohol by any person(s) involved in an accident, incident, near miss or close call where there are grounds to suspect that drugs and/or alcohol could be a contributing factor, this is conducted through post incident / for-cause screening.
- Detect the use of drugs and/or alcohol where behavioural abnormalities prompt managerial intervention (which may include for-cause screening)
A refusal to submit to testing shall lead to a positive result being recorded and shall be dealt with in accordance with the OSL Disciplinary Procedure.
If an individual believes he/she has an alcohol misuse related problem, they shall consult with their Line Manager or Human Resources as soon as possible advising of such. This will be treated in confidence and support / assistance provided by OSL. In such circumstances the individual must continue with any rehabilitation programme agreed.
This Policy will be monitored for effectiveness through internal audit and be revised as necessary.
Review of this Policy will take place at least annually or where instigated by changes to legislation, standards or accident / incident recommendations.
Document Ref: OSL/IMS/POL/001/23
OSL are committed to ensuring the effective Health, Safety, Quality and Environmental (HSQE) performance. We are all required to accept responsibility for our actions, to safeguard our own health, safety and working environment and that of our supply chain partners and public who may be affected by our activities. OSL are committed to providing a safe professicpnal service delivered by competent safetyconscious personnel to fulfil our contractual obligations, exceed customer expectations and ensure health, safety and environmental risks from our activities are identified and effectively managed as part of our journey of continual improvement. OSL will comply with all relevant legal and regulatory requirements and ensure that health, safety and welfare of its employees and other personnel are protected to a reasonably practicable level. OSL has an appointed Head of Health, Safety, Quality & Environmental as well as a HSQE Manager and Advisor.
As part of this Policy we shall:
Health and Safety (H&S)
- Arrange and implement a programme of internal audits across the business to review current processes and explore areas of improvement in line with Occupational Health and Safety management systems (OHSAS) ISO45001.
- Comply with current and applicable standards, legislation and relevant Network Rail Standards
- Provide suitable and sufficient resources to comply with our health, safety, quality and environmental responsibilities, striving for excellence. Key resources are identified on the Company Organisation Chart with aligning job descriptions
- Identify hazards / risk through risk assessment to protect our workforce and contractors, encouraging core team involvement in the risk assessment process
- Maintain compliance with Railway industry Supplier Questionnaire Scheme (RISQS) requirements through both internal and external audit
- Monitor H&S performance through Site Supervision, Surveillance Visits & Senior Leadership Tours to ensure continual improvement of our health & safety processes /procedures
- Set SMART objectives with the aim of continual improvement, the HSQE Manager will monitor action status on a regular basis to monitor performance and discuss details as part of the Management Review Meeting
- Empower OSL personnel to strive to build excellent relationships with local communities and stakeholder partners
- Implement a programme of behavioural based safety awareness to support open and honest reporting of accidents / incidents as part of our Just Culture approach
- Ensure all new OSL personnel will attend an induction presentation.
- Encourage personnel innovations, involvement, participation and cooperation through employee feedback process, summary feedback of items raised will be issued by the HSQE Manager as part of OSL’s Communication Strategy
- Communicate information regarding health and safety to OSL personnel in accordance with our Communication Strategy
- Provide suitable and sufficient Personal Protective Equipment (PPE) for our tasks /activities and ensure our personnel are suitable trained on correct use
- As part of OSLs zero accident goal, investigate accidents, incidents, near misses, dangerous occurrences and significant close calls with corrective actions implemented as required, this will be conducted by the HSQE Manager in consultation with the Company Directors
- Resource and commit to maintaining appropriate international Occupational Health and Safety accreditations.
Quality
- Arrange and implement a programme of internal audits across the business to review current processes and explore areas of improvement in line with Quality Management Systems (QMS) ISO9001.
- Where a non-conformance is identified, implement measures to rectify in consultation with the relevant department / stakeholders
- Review suppliers and contractors to be appointed / procured by OSL to ascertain quality, competence and performance to ensure services / materials / equipment are of a high standard
- Focus on continual improvement of our product and services for both our internal and external customers through sharing lessons learnt internally and with relevant stakeholders.
- Resource and commit to maintaining appropriate international quality accreditations.
- Produce Project Specific Quality Management Plans for each project when acting in capacity of Principle Contractor, to define specific requirements and deliverables for the project.
Environmental
- Arrange and implement a programme of internal audits across the business to review current processes and explore areas of improvement in line with Environmental Management Systems (EMS) ISO14001.
- Regularly assess environmental aspects and impacts associated with our projects and activities and improve on current controls from lessons learnt
- Identify any potential of pollution from our activities, ensuring these are prevented or effectively controlled.
- Produce Project Specific Environmental and Social Management Plans for each Project when acting in capacity as Principal Contractor, detailing all environmental management arrangements and responsibilities
- Continually reviewing the potential for reduction in energy use and explore energy efficiencies to minimise such use.
- Promote recyclable and renewable materials during design phases
- Employ waste minimisation techniques.
- Provide environmental instruction and information to OSL personnel as required on environmental arrangements
- Monitor emissions such as noise/light/dust from our activities ensuring Best Practical Means (BPM) approaches are adopted
- Resource and commit to maintaining appropriate international environmental accreditations.
The Head of HSQE has delegated authority to review and improve the HSQE Integrated Management System as required and as such has responsibility for communicating and supporting the implementation and maintenance of our management system. We will provide opportunity for OSL employees to provide input to Company processes and procedures through consultation. This Policy shall be communicated throughout the organisation in accordance with OSLs Internal Communications Strategy. This Policy will be reviewed at least annually or where instigated by changes to legislation, standards, Organisation activities or risks associated with such activities.
Document Ref: OSL/IMS/POL/004
OSL promote and enforce rigorous health, safety and wellbeing for all personnel and its supply chain partners, to ensure the workforce are operating within a safe working environment.
Network Rail Company Standards, Fatigue Risk Management – NR/L2/OHS/003 and
Guidance on the Management of Door to Door Work and Travel Time – NR/GN/INI/001, Transport For London Quality Environment Safety and Health Standard (QUENSH) S1552 Standard have been consulted during the production of this Policy.
This Policy considers the safety of personnel travelling to and from their place of work and strives to reduce instances of fatigue during travelling time.
To achieve this OSL personnel and our supply chain partners shall apply the following criteria at all times:
- Personnel required to drive for a period of more than two hours each way to and from their place of work (not on a 12-hour shift) shall utilise local accommodation to ensure they maintain the required level of fitness to perform their duties safely without fatigue.
- Personnel driving to and from their place of work shall stop at a suitable location and take a rest period of at least fifteen minutes after driving for a period of two hours.
- Personnel shall not exceed 12 hours travelling from ‘door to door’ including the shift working time, that is no more than an hour’s travel each way on a 10-hour shift.
Managers and Supervisors shall ensure that when selecting personnel for specific works to meet Company and Customer requirements, they give consideration and preference to personnel residing closest to the worksite location. This will prevent fatigue by reducing the amount of travelling to and from the place of work.
This Policy shall be consulted and communicated to all employees and contractors as part of their Company induction and posted on Company Intranet and Safety notice boards.
Review of this Policy will take place annually as a minimum or where instigated by changes to legislation, standards or accident / incident recommendations.
Document Ref: OSL/IMS/POL/007/23
OSL promote, enforce and encourage a Work Safe Policy to allow personnel and subcontractors to carry out work activities without risk to their health, safety or welfare.
Where individuals feel that such work operations / activities will present a risk to their health, safety and welfare they have a right to refuse to work without recourse, until the matter is resolved, and a safe working environment is established.
This Work Safe Policy shall be implemented without recourse to discipline and we shall provide our full support to personnel and our supply chain partners through an escalation process to resolve the issue raised.
Any member of OSL or its supply chain partners personnel who has a justified reason to believe that an activity or safe system will expose themselves or others to unsafe conditions and / or unsafe acts shall:
- Immediately stop work
- Ensure that actions are taken to prevent injury and ill health
- Prevent other individuals / parties from accessing any unsafe condition
- Report the circumstances to their Person In Charge (PIC), Team Leader, Supervisor or Manager
Where no satisfactory outcome is achieved the matter shall be escalated to the Company Directors / Senior Leadership Team and Health, Safety Quality and Environmental (HSQE) Manager for further investigation.
All personnel including supply chain partners and visitors are responsible for complying with the requirements of this Work Safe Policy.
All personnel and supply chain partners shall be made aware of the Confidential Incident Reporting and Analysis System (CIRAS) during our Company induction, current contact details are: 0800 4 101 101, Text Line: 07507 285 887. www.CIRAS.org.uk
This Work Safe Policy shall be consulted, communicated and issued to all personnel and supply chain partners as part of their Company Induction and posted on HSQE Notice Boards and the Company Sharepoint.
This Work Safe Policy will be reviewed at least annually or where instigated by changes to legislation, standards, organisation activities or risks associated with such activities.
Document Ref: OSL/IMS/POL/005
OSL adopt a ‘Just Culture’ Policy whereby the business is always endeavouring to learn from previous events on our journey of continual improvement and to improve our safe systems of work and business maturity.
It is also our commitment to encourage all our employees to engage and share new ideas and initiatives with pro-active feedback for business improvements. It is also important that our core team are actively involved in the risk assessment process and provide input into the safe systems of work.
We encourage our workforce to be open and honest when reporting of accidents / incidents and Close Calls to enable the business to actively identify ways to prevent further occurrence and share lessons learnt both internally and with our business partners.
The ‘Just Culture’ Policy doesn’t instigate the disciplinary procedure in event of genuine lapses or mistakes, but identifies underlying reasons in human behaviours as to why the event took place and implement sensible measures to improve and prevent further occurrence.
As part of the company accident / incident investigation procedure, OSL adopts the consequences matrix model to fairly identify the level of individual responsibility / accountability into the event and makes its decision-making process based on these findings.
In the event an individual knowingly and deliberately contravening company processes / procedures, or Network Rail / TfL Rules & Regulations, and in doing so injures himself or others, the individual/s will be subject to the OSL disciplinary procedure.
Document Ref: OSL/IMS/POL/008/23
OSL are committed to working for today’s environment and that of future generations and recognises and embraces all Rail industry initiatives promoted by Infrastructure owners, clients and delivery partners.
With this in mind, OSL are working strategically to operate in an efficient manner taking into consideration our own on, and off-site activities, and the impact we may have on our environment.
We are engaged with improving the environment and have developed a Sustainability Action Plan to assist our business in achieving our environmental / sustainable goals, detailing key areas for which we can improve with agreed Science Based Targets, that are both challenging but achievable. Individuals within our business are provided with actions and the responsibility to champion relevant areas to successful conclusion and to become part of protecting and sustaining our environment.
We are committed to working with local communities in areas we can improve and support with initiatives and development. We will endeavour to minimise nuisance disruption and environmental damage when at site. We support local charities to assist in causes and strive to build excellent relationships.
In order to support the fight against climate change, OSL has committed to achieving Net Zero emissions at the latest by 2050.
To achieve this objective, OSL accounts for its Greenhouse Gas Emissions annually and has developed a Carbon Reduction Plan with short-term and long-term targets.
Fuel combustion has been identified as a main cause of OSL emissions and therefore we will make a focussed efforts to reduce fuel consumption, including the electrification of our car fleet.
OSL will endeavour to use local workforce where practical to support local communities and reduce travel requirements removing both fatigue effects and CO2 emissions. We will continue to work with our clients, external providers, supply chain and partners on protecting and sustaining our environment and share best practice, innovation and ideas in a positive and collaborative manner. We will work to use local suppliers where practical to reduce transportation distances required for equipment purchased and support local businesses.
Robust ecological survey’s will be undertaken where applicable and project teams will continue to promote an onsite environment that is rich in flora and fauna.
We are committed to reducing the amount of mixed waste to landfill and working to forecast waste streams and segregate in a sensible manner. We will plan to recycle waste materials where possible, such as metal, cardboard and plastics to support our goal. OSL will look to use sustainable materials and equipment during the design phases.
We are working to provide non-transient sites with mains connections for both potable water and electricity where practical, this will remove the use of diesel generators and reduce our carbon footprint and protect against greenhouse gases. Where this is not practical, we will endeavour to use energy saving generators that operate more efficiently.
Document Ref: OSL/IMS/POL/003
Introduction
The Company is committed to the highest standards of ethical conduct and integrity in its business activities and as such, we will not tolerate any form of bribery within our Organisation or directed to any person within our Organisation.
Every employee and individual acting on the organisation’s behalf is responsible for maintaining the organisation’s reputation and for conducting company business honestly and professionally.
The Bribery Act 2010 came into force on 1st July 2011 which made it a criminal offence to offer, promise or accept a bribe. All employees and associated persons are required to comply with this policy, in accordance with the Bribery Act 2010.
What is a bribe?
A bribe is a financial advantage or other reward that is offered to, given to, or received by an individual or company (whether directly or indirectly) to induce or influence that individual or company to perform public or corporate functions or duties improperly.
Employees and others acting for or on behalf of the organisation are strictly prohibited from making, soliciting or receiving any bribes or unauthorised payments.
As such you should not offer, promise, give, request, agree to receive, or accept any bribes:
During the course of employment;
When conducting company business; or
When representing the organisation in any other capacity.
Procedure for offering or accepting gifts, hospitality etc.
Any gifts, rewards or entertainment received or offered from clients, public officials, suppliers or other business contacts should be reported immediately to your Manager.
In certain circumstances, it may not be appropriate to retain such gifts or be provided with the entertainment and employees and associated persons may be asked to return the gifts to the sender or refuse the entertainment, for example, where there could be a real or perceived conflict of interest. As a general rule, small tokens of appreciation, such as flowers or a bottle of wine, may be retained by employees.
If you wish to provide gifts to suppliers, clients or other business contacts, prior written approval must be obtained from the Manager. These will be authorised only in limited circumstances and must be proportionate, reasonable and made in good faith.
Reporting suspected bribery
You should report any concerns that you may have to the Manager as soon as possible. Issues that should be reported include:
any suspected or actual attempts at bribery;
concerns that other employees or associated persons may be being bribed; or
concerns that other employees or associated persons may be bribing third parties, such as clients or government officials.
In line with our whistle-blowing policy any person who reports instances of bribery or suspected bribery in good faith will be supported by the Company. We will take your concerns seriously and will ensure that you are not subjected to detrimental treatment as a consequence of your report. An instruction to cover up wrongdoing is itself a disciplinary offence. If told not to raise or pursue any concern, even by a person in authority such as a manager, you should not agree to remain silent.
Action by the company
We will fully investigate any instances of alleged or suspected bribery. Employees suspected of bribery may be suspended from their duties while the investigation is being carried out. The Company will invoke its disciplinary procedures where any employee is suspected of bribery, and proven allegations may result in a finding of gross misconduct and immediate dismissal.
Any instances of detrimental treatment by a fellow employee towards any person who raises their concerns will be treated as a disciplinary offence.
The Company may also report any matter to the relevant authorities, including the Director of Public Prosecutions, Serious Fraud Office, Revenue and Customs Prosecutions Office and the police. The Company will provide all necessary assistance to the relevant authorities in any subsequent prosecution.
Penalties.
A breach of the organisation’s anti-bribery policy by an employee will be treated as grounds for disciplinary action, up to and including dismissal.
You should be aware that that bribery is a criminal offence that may result in up to 10 years’ imprisonment and/or an unlimited monetary fine for the individual accepting, offering or attempting to cover up a bribe along with an unlimited fine for the organisation.
Records
Accurate, detailed and up-to-date records of all corporate hospitality, entertainment or gifts accepted or offered must be kept.
If you are offered any gift or hospitality, you should report the matter to the Manager. A record of all offers will be kept.
If you offer any gift or hospitality to any person, or organisation, you must first obtain permission from the Manager again the offer must be properly recorded.
Document Ref: OSL/IMS/POL/004
Purpose
We are committed to promoting equality and diversity and promoting a culture that actively values and recognises the differences between backgrounds and cultures and the valuable experiences and insights that this offers to the work place. Our aim is to manage diversity successfully to help our Company nurture creativity and innovation, thereby allowing us to tap hidden capacity for growth and improved competitiveness.
The Company aims to offer an inclusive environment in which diversity is valued and used in a respectful way to create an effective and efficient workplace and recruit and retain a diverse workforce that reflects the community that we serve. We aim to ensure that all employees have the opportunity to maximise their potential and enhance their self-development and their contribution to the Company.
To that end the purpose of this policy is to provide equality and fairness for all employees and ensure that no employees receive, either directly, indirectly or by association, less favorable treatment based on age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, sexual orientation, or perceived sexual orientation. These characteristics listed are known as the Protected Characteristics.
All employees, whether full time, part time or temporary, will be treated fairly and with respect and the Company will proactively tackle any discrimination or disadvantage.
This policy and any other relevant procedures will operate in accordance with the statutory requirements of the Equality Act 2010 and any other relevant statutory requirements.
Our Commitment:
- To create an environment in which individual differences and the contributions of all staff are recognised and valued;
- Every employee will be entitled to a working environment that promotes respect and dignity and an absence of any form of intimidation, bullying or harassment;
- All staff will have access to training, development and progression opportunities;
- There will be equality throughout the Company;
- Our rules procedures and practices will be reviewed regularly to ensure fairness;
- Breaches of our equality policy will be regarded as misconduct and could lead to disciplinary proceedings; and
- This policy will be reviewed regularly.
Who Does This Policy Apply To
This policy will apply to all individuals within this organisation and each individual is responsible to ensuring that they are compliant with this policy during their time at work. All individuals within the organisation should, and will be encouraged to, promote the aims of this policy. We will also encourage any external individuals and Company’s associated with this Company to promote the values of this policy.
Who Is Responsible For This Policy
The Directors has overall responsibility for the effective operation of this policy and for ensuring that it complies with all relevant legislation. The Directors may from time to time delegate the day to day operation of this policy to another employee.
All managers or people with responsibility for other employees are expected to set an appropriate standard of behaviour for other employees and lead by example. They also have a responsibility to ensure that those they are responsible for are adhering to the aims of this policy.
What is Equality and Diversity?
Equality is ensuring that all individuals or groups of individuals are treated fairly with attention being paid to their specific needs with regard to the above Protected Characteristics.
Diversity is a recognition and respect for the value of the differences between people to allow all to realise their full potential and an ability to promote and inclusive culture where all can contribute to the effective running of the Company. Equality and diversity are dependent upon each other to be successfully present within our Company and both should be adhered to.
Discrimination
You must not unlawfully discriminate against other people including, but not limited to, current and former employees, job applicants, clients, customers, suppliers, sub-contractors, visitors or any other person associated with the Company. This applies whether you are at your normal place of work, at another site whilst representing the Company or at any work related events including social events.
There are a number of forms of discrimination and this policy prohibits any of these forms, as detailed below, and you should be aware that they are all unlawful.
Direct Discrimination
Direct discrimination is the less favourable treatment of a person due to one of the Protected Characteristics. This can be during employment or in recruitment.
Indirect Discrimination
Indirect Discrimination is a procedure, rule, provision, criteria or policy etc. that applies to everyone but will have an adverse effect on people who possess one of the Protected Characteristics more than people without which cannot be justified.
Victimisation
Victimisation is treating someone less favourably on retaliation for a complaint made or support of a complaint made about discrimination or harassment.
Disability Discrimination
Disability Discrimination can be both direct and indirect discrimination which allows any less favourable unjustified treatment because of a disability and failing to make any reasonable adjustments to lessen any disadvantages caused.
Harassment
We have a separate policy to deal with harassment and bullying and you should refer to that policy for definitions and details.
Recruitment and Selection
The Company will uphold equal opportunities for all during the recruitment, promotion and selection for redundancy process. Candidates will be recruited solely on their own merits and their ability to carry out the job role.
Recruitment and selection will be made by matching the best person to the job role.
We will aim to take steps to ensure that knowledge of vacancies reaches a wide labour market and, where relevant, groups under-represented in the Company. Advertisements will be worded in a way so as not to discourage particular groups from applying. A copy of this policy may be made available on request.
Where appropriate, use may be made of lawful exemptions to recruit suitably-qualified people to cater for the special needs of particular groups.
Interview questions and selection processes will all be relevant to the job and will not be of a discriminatory nature. Questions will not be asked that may imply an intention to discriminate on the grounds of any Protected Characteristics.
Applicants will not be asked about their health before a job offer is made. There may times where this is required to establish if an applicant is able to perform a fundamental part of the job subject to reasonable adjustments or to assess the reasonable adjustments required. Where necessary job offers may be made on the condition of a medical check.
Short listing and interviewing of candidates will be carried out by more than one person where possible.
The Company will be required by law to ensure that all employees are entitled to work in the UK. All prospective employees, regardless of nationality, will be required to produce original documents before their employment starts to satisfy this requirement such as a passport. We will not at any time make assumptions as to nationality based on appearance or perceived nationality. A list of appropriate documentation is available from your Manager.
To ensure effective operation of this policy and to identify groups that may be underrepresented or disadvantaged within our Company we may monitor applicants gender, ethnic group, any disabilities, sexual orientation, religion and age using our Equal Opportunities Monitoring Form. Requests for this information will be anonymous and will have no bearing on the applicants’ chance of success. No applicant will be required to give this information and completion of the form will be voluntary.
The recording of this information will be solely for the purpose of monitoring and to take appropriate steps to avoid any discrimination and improve equality and diversity within the Company. Such monitoring will not be used as part of the selection criteria for selection of new staff or for selection of existing staff for training or promotion opportunities, or any other decision related to your employment with us. All information gathered is stored separate from your personnel file and application forms.
Training and Promotion
Any opportunities for training within the Company will normally be made known to all employees. We will also endeavour to identify any training needs of employees.
You will be given appropriate access to training in order to help you progress within the Company. Selection for training will be made in line with this policy and will be made solely on the merits of the particular situation.
All vacancies will be advertised internally and individuals given the opportunity to apply for any posts. Selection for interview will be in line with the recruitment and selection details above.
We will monitor the structure of the Company at all levels and where appropriate we will take steps to ensure that there are no unjustifiable barriers to promotio0n and to ensure that disadvantaged or underrepresented groups needs are met.
Third Parties
Discrimination against an employee by any third party, whether a customer, client, supplier or any other associated person or company will not be tolerated. Any concerns/complaints regarding discrimination should be raised with your Manager.
Where an employee is subjected to discrimination by a third party with whom the Company associates who is not an employee, the Company will endeavour to take all reasonable steps to ensure that that such discrimination does not continue or occur again,
Termination of Employment
Should it become necessary to make any employee(s) redundant, we will apply a criteria and procedures that are fair and objective and look solely at the merits of each person. Procedures and criteria applied will not be directly or indirectly discriminatory.
Any disciplinary procedures and or penalties applied will also be done so without any discrimination whether this results in warnings up to and including dismissal.
Disabilities
We will endeavour to support you and consider any reasonable adjustments should you have a disability. If you are disabled or become disabled, we encourage you to speak to your Manager so that we can evaluate the situation. If you experience any difficulties at work in relation to a disability you should contact your Manager to discuss any reasonable adjustments that would assist in minimising the effects.
Your Manager may wish to consult with you and your medical advisor about possible adjustments. If the Company are unable to make an adjustment and deems it to be unreasonable, we will explain our reasons in full and discuss alternative solutions where possible.
We will endeavour to make access to and around our premises easy and avoid any potential disadvantages. Where necessary we will ensure that any reasonable changes are made to the access to limit any disadvantages.
Part-time and Fixed-Term Work
Any employees engaged to work on a part-time or fixed term basis will not suffer any detrimental or less favourable treatment than those engaged to work on a full-time basis. Any benefits applicable to employment will be received, on a pro-rata basis, by all employees whether part time, full-time or fixed term subject to any conditions on length of service applied to all employees.
Breaches of this Policy
Any breaches of this policy will be considered a serious matter and will be dealt with under our disciplinary procedures as detailed in the Employee handbook. Serious breaches of this policy and deliberate discrimination may be considered gross misconduct and may result in dismissal.
If you believe that you have suffered a detriment or any other adverse effect due to discrimination you should raise the matter through our grievance or harassment and bullying procedure as detailed in your Employee handbook.
Whilst we will support all parties during and after a thorough and objective investigation into the allegation as appropriate, if through the course of the investigation and subsequent disciplinary meetings evidence demonstrates that the allegation has been made maliciously, or for personal gain, then the individual making the complaint will be subject to Disciplinary proceedings as outlined in the Company’s Disciplinary Policy.
Document Ref: OSL/IMS/POL/005
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chain.
OSL are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain. We expect the same high standards from all of our contractors, suppliers and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude and we expect that our suppliers will hold their own suppliers to the same high standards.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors, external consultants, third-party representatives and business partners.
This policy does not form part of any employee’s contract of employment and we may amend it at any time. Management at all levels has responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
Management at all levels have day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given any required training.
The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify your Manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. You are encouraged to raise concerns about any issue of suspicion of modern slavery in any parts of our business or the supply chains of any supplier tier at the earliest possible stage.
If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your Manager or report it in accordance with our Whistleblowing Policy as soon as possible.
If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chain constitutes any of the various forms of modern slavery, raise it with your Manager.
OSL aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any part of our supply chain. If you believe that you have suffered any such treatment, you should inform your manager immediately.
Training on this policy, and on the risk our business faces from modern slavery in its supply chain will be given where needed.
Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Any employee who breaches this policy may face disciplinary action, up to and including dismissal.
We may terminate our relationship with other individuals and organisation’s working on our behalf if they breach this policy.
Document Ref: Carbon Reduction Policy
Introduction
The UK Government amended the Climate Change Act 2008 in 2019 by introducing a target of at least a 100% reduction in the net UK carbon account (i.e. reduction of greenhouse gas emissions compared to 1990 levels) by 2050. This is otherwise known as the ‘Net Zero’ Target.
Action Note PPN 06/21, “Procurement Policy Note – Taking Account of Carbon Reduction Plans in the procurement of major government contracts,” sets out how to take account of suppliers’ Net Zero Carbon Reduction Plans in the procurement of major government contracts.
This plan outlines OSL’s compliance with Action Note PPN 06/21.
Commitment to achieving Net Zero
OSL Global is committed to achieving Net Zero emissions by at the latest by 2050.
You can read more about our Corporate Social Responsibility, here.
Managing Fatigue/Working Hours Policy
OSL manages the working times of its personnel and supply chain partners to meet compliance of relevant standards and legislation, Network Rail Company Standard NR/L2/OHS/003 Fatigue Risk Management and Control of Working Hours for Staff Undertaking Safety Critical Work’ and Transport for London Quality Environment Safety and Health (QUENSH) S1552 Standard.
OSL operates a Fatigue Management Procedure (OSL P HSQE 007) which details the requirements to control the effects of fatigue from working hours, this has been produced to ensure our employees don’t exceed maximum working hours as detailed below and in accordance with recent industry changes.
Where this is not practical due to exceptional circumstances arising, an assessment of the risk must be carried out and controls and measures introduced to reduce the effects of fatigue risk as low as reasonably practical.
The Working Time limits which shall apply are detailed in NR/L2/OHS/003, and QENSH S1552, with an exception that it is OSL Policy that employees will, wherever practicable work a maximum of 60 consecutive hours.
OSL also maintain an Opting Out process which complies with the HSE’s Working Time Directive.
Exceeding working time limits
During exceptional circumstances and where no alternative arrangements can be made, the limits shown in Procedure OSL P HSQE 007 may be exceeded where authorised by the Line Manager or Nominated Supervisor.
In such circumstances, the person authorising the exceedance above must carry out a risk assessment using the OSL Working Hours Exceedance Form and record the findings / control measures for each individual required to work for suitability and fitness when working in excess of the pre-planned hours.
Exceeding working time limits
During exceptional circumstances and where no alternative arrangements can be made, the limits shown above may be exceeded where authorised by the Line Manager or Nominated Supervisor.
In such circumstances, the person authorising the exceedance above must carry out a risk assessment using the OSL Working Hours Exceedance Form and record the findings / control measures for each individual required to work for suitability and fitness when working in excess of the pre-planned hours.
Staff and supply chain partners responsibility
Staff and supply chain partners must inform OSL of any other work they may carry out for other companies that may have impact on the working hours stipulated above, regardless of whether it is railway related or otherwise.
If there are any concerns, there is a dedicated managing fatigue e-mail address which comes directly to HSQE staff at: fatigue-issues@oslglobal.com