Others Policy

Klaspad requires CEOs, officers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of Klaspad requires CEOs, officers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of Klaspad, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

The aim of this policy is to:

• ensure all employees feel supported in speaking up in confidence and reporting matters they suspect may involve anything, improper, unethical or inappropriate;
• encourage all improper, unethical or inappropriate behaviour to be identified and challenged at all levels of the organisation;
• provide clear procedures for the reporting of such matters;
• manage all disclosures in a timely, consistent and professional manner; and
• provide assurance that all disclosures will be taken seriously, treated as confidential and managed without fear of retaliation.

Reporting Responsibility

This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that Klaspad can address and correct inappropriate conduct and actions. It is the responsibility of all board members, officers, employees and volunteers to report concerns about violations of Klaspad’s code of ethics or suspected violations of law or regulations that govern our operations.

No Retaliation

It is contrary to the values of Klaspad for anyone to retaliate against any board member, officer, employee or volunteer who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of Klaspad. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.

Reporting Procedure

Klaspad has an open door policy and suggests that employees share their questions, concerns, suggestions or complaints with their supervisor. If you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with the CEO or board member. Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to Klaspad’s designated employee or board member, who has the responsibility to investigate all reported complaints. Employees with concerns or complaints may also submit their concerns in writing directly to their supervisor, Managing Director or CEO.

In case of emergency, CEO should be informed immediately for further actions.

Compliance Officer

Klaspad's Compliance Officer is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The Compliance Officer will advise the CEO and/or the Board of Directors of all complaints and their resolution and will report at least annually on compliance activity relating to accounting or alleged financial improprieties

Accounting and Auditing Matters

Klaspad's Compliance Officer shall immediately notify the CEO of any concerns or complaint regarding corporate accounting practices, internal controls or auditing and work with the committee until the matter is resolved.

Acting in Good Faith

Anyone filing a written complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offence.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations

Klaspad's Compliance Officer will notify the person who submitted a complaint and acknowledges receipt of the reported violation or suspected violation. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.

Compliance Officer:

The Compliance Officer may be a board member, with the exception of the CEO, or a third party designated by the organisation to receive, investigate and respond to complaints.

Review

This policy will be regularly reviewed, in the light of experience. Comments and contributions on the policy from staff, stakeholders and the public are welcome at any time.

Introduction

Klaspad will complete risk assessments to ensure that all hazards to be found in the workplace are either eliminated or remedial actions implemented to reduce the level of harm to a minimum. Following the risk assessment, where required, safe working procedures will be written and provided to all appropriate personnel.

In assessing the risks in the workplace, Klaspad will:

• look for the hazards;
• decide who might be harmed and how;
• identify the likelihood of the hazard causing harm
• determine the seriousness of the injury
• decide whether the existing precautions are adequate or whether more should be done;
• record the findings;
• review the assessment and if necessary, revise it.

Looking for Hazards

Klaspad will determine the hazards by:

• consultation and conducting inspections of the workplace;
• analysing jobs;
• adopting a “what if” approach;
• listing all Acts and Regulations as they apply to the workplace.

Evaluating the Risks

For any hazards, the existing precautions will:

• Meet the standards set by legislation
• Comply with a recognised industry standard
• Represent good practice
• Reduce risk as far as reasonably practicable

Recording the Findings

Klaspad will show that:

• A proper check was made.
• Persons affected are identified.
• Obvious significant hazards are dealt with; and
• The precautions are reasonable and the remaining risk is low.

Records will be kept for future reference.

Review and Revision

If there is a significant change in working practices, such as the purchase of new machinery or substances, employment of new employees, etc., that may present new hazards, then a new risk assessment will be undertaken. Amendments will not be made for trivial changes, only for significant ones.

Management of the Risk Assessment Process

Before risk assessments can be completed, the following steps must be taken:

• Identify the person responsible for the management of the risk assessment process.
• Train (where necessary) a number of personnel in the risk assessment process.
• List all risk assessments to be completed.
• Introduce a system for the completion of all remedial actions.

Procedure

• A risk assessment will be conducted using either the Area Risk Assessment Form or Task Risk Assessment Form (whichever is appropriate to the situation).
• The Area/Task Risk Assessment Form will be returned to the identified responsible person upon completion for review.
• The Health and Safety Officer will inspect and implement proposed courses of action reducing risk to as low a level as possible.
• A safe working procedure will be completed if required.
• All findings will be recorded and all risk assessments reviewed either annually or if something significant changes in the work process/area.

Area Risk Assessment Form

This form is to be completed when undertaking a risk assessment for an area or department.

Task Risk Assessment Form

This form is to be completed when undertaking a Task Risk Assessment

Introduction

The Health and Safety (First Aid) Regulations 1981 and the approved code of practice require employers to provide adequate and approved equipment, facilities and personnel to enable first aid to be given to students and employees if they are injured or become ill at work.

Klaspad will, therefore, ensure that first aid arrangements comply with current legislation and any additional guidance issued by the Health and Safety Executive from time to time. First aid will be available to employees and visitors to Klaspad and when members of the organisation are on organised off-site activities.

Aims and Objectives

• Provide sufficient numbers of qualified persons to carry out first aid treatment
• Provide sufficient and appropriate first aid materials and resources
• Ensure first aid provision is available at all times while people are on the Klaspad premises and also whilst on organised trips
• Ensure compliance with relevant legislation
• Identify hazards on the premises and take appropriate action
• To keep accident records

Responsibilities

The CEO and Officers of Klaspad have responsibility for ensuring health and safety of the community and oversee day to day implementation of first aid.

Copies of the First Aid Policy are available on the web-site and offices. All staff should familiarise themselves with the policy so they are aware of their responsibilities and the prevailing procedures and practices.

Qualifications and Training

First aiders hold a valid certificate of competence as recognised by the HSE and undergo regular retraining to ensure compliance with the legal requirements. As these are voluntary positions, appropriate arrangements will be made for staff to attend refresher and retraining courses as necessary.

Provision

Klaspad is a low risk institution and as such, there is only need for one qualified first aider per 50 to 100 people. The list of first aiders and locations for contact is found in the Appendix 1.

First Aid Cover

There is a first aid kit located in the office. Other kits are available around the premises. The content of each kit is checked once every academic term and replenished as necessary.

Records

The records of first aid treatment and the Accident book are located in the main office. The records are normally kept for three years. Instructions for the completion of these records books are located at the front of each book. The record of any accident or injury with a health and safety concern is passed to the CEO for review and appropriate action as necessary.

Signposting

The location of the first aid kit in the office clearly marked, in line with current guidance.

Information on Medical Conditions

If an employee member has a declared medical condition, this will be recorded in their employee file/profile and the CEO will be made aware (from the administration team). If an employee has a serious medical condition, such as epilepsy, then all staff members will be notified to ensure that in the event of an emergency everyone is aware. Staff member files are located in the administration department and when any member of staff becomes aware of a condition not recorded, they should inform administration to update the records.

Any member of staff in charge of an offsite visit must obtain medical information on participating staff members, including details of any medical requirements and appropriate emergency contact details prior to the activity taking place. This information can be obtained from the administration. If whilst on a trip, a staff member is to be on their own, they must have access to a telephone to summon help if needed.

It is Klaspad policy not to administer drugs or other forms of medication. However, individuals may be assisted by a qualified first aider to take their own medication if necessary, for example asthma pump. Special arrangements may be available for staff members with specific needs, but these must be discussed with Klaspad in advance.

First Aid

First aid is an emergency treatment given to an injured or unwell person before professional medical care is available. The qualified first aider will assess the situation and decide on the level of treatment necessary. However, any individual who has received head injuries will be referred for urgent medical assessment with their GP or NHS A&E as appropriate. Where hospital treatment is necessary, next of kin are to be informed. Any member of staff who feels unwell should report to the administration team and help will be called. Controlling the risk of infection from human bodily fluids

1. Accidents and incidents involving the risk of blood borne infection These include:

• sharps injuries;
• needle injuries;
• contamination of cuts or abrasions;
• mucous membrane entering the eyes and/or mouth containing blood or body fluids. The infection control procedure is as follows:

Go to the nearest sink:

• For skin injury or wound contamination, encourage the wound to bleed for 1 minute under warm running water but DO NOT suck it;
• For contamination in the eye or mouth, irrigate eyes with water and rinse the mouth thoroughly;
• Wash the wound thoroughly using soap and warm running water.

b. Request a First Aid Officer to lightly cover the wound with gauze from a first aid box;

c. nform your manager, first aider or CEO who should ensure that the contaminant is safely disposed of into a sharps box/clinical waste bag as appropriate and ensure that an accident report form is completed as soon as possible;

d. Contact your general practitioner (GP) as soon as possible for advice. If they are not available, go to the local accident and emergency department to obtain further guidance.

2. Cleaning up spillages of blood, vomit and excreta

The infection control procedure is as follows:

• Keep people away from the contaminated area;
• Cover all breaks in the skin with waterproof plasters;
• Wear disposable blue nitrile gloves and a disposable apron;
• Where splashing is possible, protect eyes and mouth with a visor;
• Avoid hand-mouth contact and hand-eye contact;
• For blood spills:

• Use diluted bleach (1 part bleach to 10 parts water) in a bucket of warm water;
• Carefully pour the dilute mixture gently over the spill;
• Cover with disposable towels;
• After 2 minutes mop up using more disposable towels.

• g. For vomit and excreta spills remove gross contamination using plenty of paper towels;
• h. Clean affected area with detergent;
• i. Dispose of all waste into a clinical yellow bag and seal;
• j. Dispose of any used gloves, aprons, mop heads and cloths into the clinical yellow bag;
• k. Wash hands thoroughly with antibacterial soap and water.

3. Urine spillages

The infection control procedure is as follows:

• Keep people away from the contaminated area;
• Cover all breaks in the skin with waterproof plasters;
• Wear gloves and disposable aprons;
• Where splashing is possible, protect eyes and mouth with a visor;
• Avoid hand-mouth contact;
• Do not use bleach as this may result in a dangerous chemical reaction;
• Use paper towels to mop up the urine;
• Clean the area with detergent;
• Dispose of all waste into clinical yellow bags;
• Dispose of any used gloves, aprons, mop heads and cloths into the clinical yellow bag and seal;
• Wash hands thoroughly with antibacterial soap and water.

4. Safe disposal of contaminated sharps, used needles, etc.

The infection control procedure is as follows:

• Keep people away from the area;
• Wear disposable gloves;
• Handle sharps/needles with care. If possible pick up from the non-contaminated/non-sharp end. Make use of tweezers if available;
• Dispose of sharps into a sharps box;
• Any other items that may be contaminated with blood or body fluids should be disposed of into a yellow clinical waste bag and sealed;
• Wash hands thoroughly with antibacterial soap and water;

Review

This policy will be regularly reviewed, in the light of experience. Comments and contributions on the policy from staff, stakeholders and the public are welcome at any time.

Introduction

The success of Klaspad relies on its ability to attract the best staff and volunteers available. Recruitment methods must be fair, efficient, and effective.

Policy

The Staff Recruitment Policy has been established to ensure Klaspad has the opportunity to attract the best available staff and volunteers for all vacant positions. This policy relates to employment of all staff and volunteers other than the CEO.

Klaspad is committed to providing high quality programs and services to our community. To support the achievement of this objective we recognise the importance of employing the most suitable applicant for all vacant positions.

Klaspad will ensure it has the best opportunity to attract the best available staff by broadly advertising (internally and externally as deemed appropriate) all vacant remunerated positions and volunteer vacancies. Klaspad will take all reasonable steps to ensure that applicants may be safely entrusted with the duties of their position.

Klaspad will internally advertise all vacant positions to current staff and volunteers to encourage career advancement and increase participation.

Klaspad is committed to providing a work environment that is free from harassment and discrimination. All recruitment and selection procedures and decisions will reflect Klaspad’s commitment to providing equal opportunity by assessing all potential candidates according to their skills, knowledge, qualifications and capabilities. No regard will be given to factors such as age, gender, marital status, race, religion, physical impairment or political opinions.

Responsibilities

It shall be the responsibility of the CEO to implement this policy and to monitor its performance. We will have a Human Resources Department when the number of staff is above 20. Up to 20 staff members we will use external advisors.

It is the responsibility of Managers and Supervisors to ensure that:

• They are familiar with the recruitment policies and procedures, and that they follow them accordingly;
• Staffing levels for their department are determined and authorised;
• All roles have current position descriptions that specify role requirements and selection criteria. It is the responsibility of the External Advisor to ensure that:

All Managers are aware of their responsibilities in the recruitment and selection process; Managers are given continuous support and guidance in regards to recruitment and selection issues.

Procedures

Pre-Recruitment Activities

When it becomes necessary to recruit for a position, Managers should carefully consider the requirements for the position, and the key selection criteria including skills, experience and qualifications.

If no position description exists for the available position, or if it requires revising, this is the responsibility of the appropriate Manager. Once the new position description or amendments have been drafted, it should be forwarded and approved by the CEO and/or Board. Selection criteria will be drawn up based on the basis of a position statement.

Where the position description is for a new role, the Manager will review and evaluate the position and draw up a position statement that will then, if appropriate, be approved by the CEO and/or Board.

Prior to commencing the recruitment process, the responsible Manager is required to gain approval from the CEO / Board or delegated authority and forward this to the External Advisor.

Direct Internal Appointments/Promotions

In situations where a Manager wishes to promote an employee who meets the specific selection criteria for the vacant position into the internal vacancy, the appointment must be authorised by the appropriate Manager, and the approval is to be forwarded to the External Advisor and CEO.

Internal Advertising

Where appropriate, Klaspad will advertise all vacancies internally.

Exceptions to this rule may occur when:

• The position is of such a specialised nature, and / or appropriate skills are not available within the organisation; or
• There is a need to make a direct appointment or promotion into the vacant position.

Upon receiving approval for the vacant position, CEO will advertise the available position internally. Internal advertisements should include the following:

• Position title;
• Outline of the position;
• Skills required for the role;
• Closing date for applications.

All internal applicants should forward a current copy of their resume, together with covering letter, to the applicable manager for acknowledgement, consideration and processing.

Internal applicants who possess the required skills, qualifications and work-related experience, as specified in the internal advertisement, will be interviewed for the position by the relevant Manager or Supervisor.

External Advertising

Where a position cannot be filled internally or where it is appropriate to conduct an external recruitment campaign, the available position should be advertised through relevant networks, on relevant websites, and through local employment services.

Volunteer positions will be advertised as widely as deemed reasonable.

All advertisements must be approved by the CEO.

If required, the External Advisor will prepare an appropriate recruitment advertisement for the position and submit it for review and approval by the relevant Manager. The External Advisor will administer the placement of the advertisement and monitor applications received.

Screening Applicants

If the External Advisor has been engaged to recruit for a position, they will be responsible for screening the applicants.

Resumes must be screened against the position description so that assessments can be made of their suitability for the specific role. Applicants who are assessed as suitable will then be selected for interview.

Managers should consult with the CEO if they require any assistance with the selection process.

Where appropriate, but particularly in positions of financial responsibility or in dealing with vulnerable clients / children, police checks may be arranged. Police checks shall be arranged only with the consent of the applicant concerned; however, if consent is refused this shall be taken into consideration in the selection process. Previous employers and referees shall be contacted, and transcripts, qualifications, publications and other certification or documentation shall be validated.

Any checks which may form part of the selection process should be conducted prior to issuing an offer of employment.

Conducting Interviews

The short-listing and interview process will be conducted by a selection panel which will be appointed by and will include the CEO or their nominee and the relevant manager or supervisor for the position.

If any member of staff finds that they are assessing any applicant where there is a perceived or actual conflict (eg. Where the applicant is a family member, friend or past colleague) they shall declare the perceived or actual conflict to the panel.

Reference Checking

Managers are to ensure that, where possible, a minimum of two reference checks are conducted prior to an offer of employment being extended to a candidate.

Details of the reference checks should be attached to the candidate’s application for future reference.

New Starter Paperwork

If an internal candidate is selected, the Manager is required to notify the successful candidate and their Manager. If an external candidate has been selected, the Manager is to make a verbal offer to the candidate.

To authorise the commencement or transfer of an internal employee, the Manager must notify and provide confirmation of the CEO’s approval. The Manager should ensure that all recruiting documents are completed and returned to the External Advisor (later Human Resource Department) for filing.

The External Advisor (later Human Resources Department) will prepare a written letter of offer for the successful candidate. The letter of offer and or contract of employment will confirm the start date, salary (if any), position and the terms and conditions of employment pertaining to the employee.

Once the Manager has received the candidate’s signed letter of offer, the External Advisor (later Human Resources Department) is to notify all unsuccessful candidates. If an external recruitment agency has been used, the Manager is to notify the agency, who will notify the unsuccessful candidates.

The Manager is responsible for liaising with the External Advisor (later Human Resources Department) to ensure that the necessary documentation, equipment and access privileges are prepared for the new employee. The Manager will forward an induction kit to the new employee for their completion.

Records and Correspondence

All contact regarding the position is to be directed through reception, with all applications marked “Confidential” and posted to the CEO.

Letters/emails of acknowledgement should be posted to all applicants prior to the short-listing of final suitable applicants. Short-listed but unsuccessful applicants should be advised that their CV will be retained for future reference, unless the applicant advises otherwise.

Applicants who do not meet the key selection criteria and are not suitable to be short-listed for an interview should be sent a written letter advising them that their application has been unsuccessful.

Assessment Criteria & Scorecard

Shortlist Decision

Successful

Not Successful

Review

This policy will be regularly reviewed, in the light of experience. Comments and contributions on the policy from staff, stakeholders and the public are welcome at any time.

What ethics mean to Klaspad

Ethic - A moral principle or set of moral values held by an individual or group.

Values and ethics shape the way we view the world and how we behave in it. The purpose of this policy is to provide guidance to staff in assessing the many and sometimes complex decisions they have to make. It will also signal to users and observers of Klaspad that they can have confidence in what we do and the way that we do it.

What does the policy cover and who does it apply to?

This paper sets out our guiding principles, and how we intend to apply them, which together form the ethics policy of Klaspad. The policy applies to all aspects of our governance, operational and administrative activities. All those covered by the policy are personally accountable for operating within the scope and intent of the policy. It covers all Klaspad staff, whether temporary appointees or permanent at any of our operational centres. We expect those organisations whose staff (temporary or otherwise) or volunteers attend Klaspad to respect the policy, and we reserve the right to refuse access to those who don’t. We expect those officers who serve on our decision-making and advisory bodies to respect the policy.We request organisations that we work with to respect our ethical positions.

Implementation

All those covered by the policy are responsible for ensuring that activities for which they are responsible comply with this policy. People should raise concerns with line managers in the first instance. Similarly, clear breaches of the ethical policy should be referred to managers. Existing mechanisms within the organisation should be used to resolve concerns or refer onwards as appropriate. Serious or unresolved concerns should be referred to the Ethics Committee (ad hoc committee set up on demand).

Guiding Principles

The following principles provide the ethical framework that we aspire to whilst working in the UK and abroad. Our principles are to:

In relationships with others

• Treat colleagues, stakeholders, customers, suppliers and the public respectfully and professionally, taking account of confidential issues when appropriate.
• Deal courteously with those who hold opinions that differ from ours.
• Respect cultural differences.
• Klaspad has clearly worded policies for all staff, representatives and agents with respect to the promotion and marketing of education services overseas.
• Klaspad will exercise good practice to ensure fairness in promotion and marketing of services overseas with regard to:
  • Other institutions
  • The interests of both local and international customers/ suppliers.
  • The perceived quality of the system
  • The cultural relationships
• Differences between organisations will be portrayed in a comprehensible and accurate way target countries and audiences. No false or misleading comparisons are to be made in relation to other providers.
• Klaspad and officers are to conduct themselves with integrity and in a manner that will contribute to the image of a reliable and trustworthy provider of high quality system.
• Klaspad will behave toward other institutions, professional colleagues and other countries in a respectful and courteous manner.
• Klaspad and officers are to observe all other codes of practice and guidelines that may have relevance to international activities and international customers/suppliers.

In our work

• Operate with honesty and integrity in all our work, taking steps to identify and deal with corrupt practices and professional misconduct.
• Be open and transparent in making decisions, undertaking activities and allocating funding.
• Reach conclusions based on best professional practice, having considered all views.
• Work to the standards of UK legislation as a minimum here and abroad, and operate according to local laws as required.
• Disclose conflicts of interest and actively manage them.
• Ensure funding decisions are transparent and securely based on objective assessment and selection procedures.
• Recognise appropriately the intellectual and operational contributions of others.
• Consider ethical challenges which arise from new or existing proposals by broadening the debate as early as practicable.
• Klaspad will promote accurately systems in terms of quality, standing and availability.
• Selection criteria for international students should be clear, unambiguous and contribute to the maintenance of the College’s academic standards and to encourage high success rates.
• Staff members representing Klaspad overseas should be:
  • Sympathetic, clear communicators with a thorough knowledge of Klaspad procedures
  • Knowledgeable, experienced and competent in the administration of customers’ policy and in face-to-face dealings with customers.

The Ethics Committee and monitoring procedures

The Ethics Committee will be a small team comprising the CEO, one member from management and a member of staff. Serious issues which cannot be resolved via existing mechanisms may be referred to the Board at any time. Breaches of the policy which cannot be dealt with in the line management system may also be referred to the committee.

The Committee may then convene, with appropriate additional expertise if needed, to consider the issue. The Committee’s decision will be final and it will have power to take action it deems necessary.

Communicating the policy

The policy will form part of the Klaspad induction process and adhering to the policy will be part of everyone’s terms and conditions of employment.

Review

This policy will be regularly reviewed, in the light of experience. Comments and contributions on the policy from staff, stakeholders and the public are welcome at any time.

General

This policy sets out guidelines with a view to creating and maintaining a fair, just and non-discriminatory working environment within the perimeter of Klaspad. Klaspad is committed to promoting and celebrating diversity and equality of opportunity, we welcome diversity and differences as a great source of strength.

Klaspad promotes the ethos of the Equality and Human Rights Commission (EHRC) in that the College has adopted an approach to promote sensitivity to human rights and to prevent discrimination of any kind among and between its students and staff and in its dealings with other institutions and individuals.

Introduction

The policy is based on the clear aims of the company to address the need of the modern multicultural society in the United Kingdom. It also asserts the acceptance by the company of existing government and non-government instructions for streamlining this potentially sensitive issue representing all races, backgrounds and diversities in our society. Racism, sexism or treating people unfairly because of their age, class, sexuality, religion, physical or mental differences are unacceptable. We reject any behaviour or ways of working - obvious or not – which allow discriminatory practices of any description.

The policy’s aim is to:

• provide equality, fairness and respect for all in our employment, whether temporary, part-time or full-time
• Not unlawfully discriminate because of the Equality Act 2010 protected characteristics of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality, and ethnic or national origin), religion or belief, sex (gender) and sexual orientation
• oppose and avoid all forms of unlawful discrimination. This includes in pay and benefits, terms and conditions of employment, dealing with grievances and discipline, dismissal, redundancy, leave for parents, requests for flexible working, and selection for employment, promotion, training or other developmental opportunities

The organisation commits to:

• encourage equality and diversity in the workplace as they are good practice and make business sense
• create a working environment free of bullying, harassment, victimisation and unlawful discrimination
• promoting dignity and respect for all, and where individual differences and the contributions of all staff are recognised and valued

This commitment includes training managers and all other employees about their rights and responsibilities under the Equality policy. Responsibilities include staff conducting themselves to help the organisation provide equal opportunities in employment, and prevent bullying, harassment, victimisation and unlawful discrimination All staff should understand they, as well as their employer, can be held liable for acts of bullying, harassment, victimisation and unlawful discrimination, in the course of their employment, against fellow employees, customers, suppliers and the public

Take seriously complaints of bullying, harassment, victimisation and unlawful discrimination by fellow employees, customers, suppliers, visitors, the public and any others in the course of the organisation’s work activities

Statutory Obligations

• The Sex Discrimination Act 1975 and the Race Relation Act 1976 prohibit discrimination on any grounds and identifies it to be of two types - direct and indirect discrimination. Direct discrimination is assumed to be committed when an individual is treated more favourably than others.
• Indirect discrimination occurs when special conditions or requirements are applied to certain people without there being a justifiable necessity for doing so. Similarly, staff should be victimised or harassed whilst carrying out their duties.
• It should also be noted that the various Commissions have produced Codes of Practice with the objective of encouraging and promoting ‘best practice’ with regard to Equal Opportunities and Human Rights.
• The Disability Discrimination (DDA) Act 1995 defines a disabled person as a person with 'a physical or mental impairment which has a substantial and long-term adverse effect on their ability to carry out normal day-to-day activities'.
• The Human Rights Act 1998 incorporates the European Convention of Human Rights into UK law, in particular, Article 14 of the Act that prohibits discrimination.
• The Board of Directors of Klaspad require that all staff members are provided with an environment which is free of discrimination, values the qualities of an individual regardless of his or her personal orientation and has harmony amongst all as envisaged by the local laws and codes of practice.

• Discrimination within the premises. Klaspad strongly discourages the practice of discrimination by anyone within its responsibility. If there is evidence that a person has made inappropriate remarks, harassment of any description, then this will be subject to investigation and may face disciplinary action.
• Signs or Gestures. All staff are expressly forbidden to make racist remarks to others, display slogans of political nature and wear clothing and equipment with racist symbols, badges or insignia within the premises.
• Individual Attitudes. All staff are encouraged to familiarise themselves with non-discriminatory practices and all aspects of current equal opportunity requirements to assist them in changing and challenging their attitudes as necessary, so creating an environment without prejudice.
• Language. The language medium of Klaspad is English. However, the company accepts the importance and values of the native languages of individuals.
• Complaints. An individual who feels that they are the victim of discrimination within Klaspad may wish to lodge a complaint through one of the staff or directly to the CEO. Such complaints will receive the highest priority and be dealt with in confidence. An individual will have committed an offence if he or she falsely claims to have suffered discrimination and may face disciplinary action taken should this be proven.
• Policy Review. The EO policy, as other policies of Klaspad is subject to regular reviews by the Board. A revised policy will be effective as soon as it is authorised by the said board members.

Klaspad will meet all statutory obligations under relevant legislation and, where appropriate, anticipate future legal requirements. This will be informed by:

• The Equality Act (2010) and associated secondary legislation.
• Criminal Justice and Immigration Act (2008).
• The Racial and Religious Hatred Act (2006).
• The Civil Partnership Act (2004).
• The Gender Recognition Act (2004).
• Criminal Justice Act (2003).
• The Human Rights Act (1998).
• The Protection from Harassment Act (1997).
• Special Education Needs and Disability Act (2001).

Review

This policy will be regularly reviewed, in the light of experience. Comments and contributions on the policy from staff, stakeholders and the public are welcome at any time.

Definition of Disability

Disability is defined by the Disability Discrimination Act 1995 (DDA): "A person has a disability if he or she has a physical or mental impairment that has a substantial and long-term adverse effect on his or her ability to carry out normal day to day activities."

Key Objective

• Awareness: that those with a current or new disability are aware of the facilities available to them in accessing the Klaspad ’s services and employment opportunities;
• Adaptation: that employees recognise the particular needs of the disabled person and act accordingly;
• Accessibility: that any barriers to providing a full service or employment to a disabled person are identified, assessed and considered by the management team
• Aid: that any additional support (either internally or externally) to making a full service or offer of employment available to a disabled person is considered by the management team.
• Assessment: that adherence to these key principles is checked, be it though an audit or risk assessment, with results presented to a Director and also the management team at their bi-annual Health & Safety Management meeting.
• Appraisal: that both disabled and other employees will be consulted on the effectiveness of this Company’s disability symbol activities and findings considered in management meetings and any resultant actions monitored.
• Available employment: that disabled employees have an opportunity to apply for advertised internal vacancies and where there is a change to their ability they are supported in continuing their existing role, or in taking on a new role or seeking employment elsewhere.

These seven "A"s are the theme though our procedure, internal training and practice.

Procedure

Klaspad's procedure enables the policy to be implemented, reviewed and revised as appropriate. This procedure relates to the seven hey principles of the policy.

Awareness: Where an existing employee has a disability or becomes disabled they should advise their Departmental Manager so that the appropriate steps may be taken.

Where this Company provides facilities for a disabled person, steps are taken to ensure that access to its site, employment and the provision of services and products is advertised. The CEO is accountable for ensuring that such awareness is in place.

For wheelchair users a access ramp is sign-posted at the customer street entrance at eye level. The portable ramp will be brought to the customer entrance on the site of the building. There is a sign and bell (again at eye level for any wheelchair user) to gain attention.

Adaption: that employees recognise the needs of the disabled person and act accordingly. The employee requires support for such actions they should refer to their Departmental Manager. The accountability for the actions of employees rests with the CEO and Directors.

Accessibility: that any barriers to providing a full service or employment to a disabled person are identified, assessed and considered by the management team. Such consideration shall be documented either as part of an audit or risk assessment process. The accountability for any final decision rests equally with the managing director.

For wheelchair users wishing to gain access to the building there is a portable ramp which is stored in a convenient location so as to minimise any delay to the customer. This is fitted to the door at the side of the building; such fitting will be undertaken by trained employees. The ramp is of a suitable gradient and finish to ensure both the effort required by the disabled person and risk of wheel slippage is kept to the minimum. Employees must not attempt to manoeuvre a wheelchair or provide any assistance other than at the express wishes of the disabled person as they may be offended or even cause an accident.

Aid: that any additional support (either internally or externally) to making the full service available to a disabled person is considered by the management team. The CEO is accountable for ensuring that such consideration is undertaken and includes awareness/ training to both customers and employees as appropriate. For those likely to be assisting wheelchair users there is a requirement to undertake the company's training on use of the portable ramp; once completed this is entered onto the company's Training Matrix under “Use of Access Ramp".

Assessment: that adherence to these principles is checked, be it thought either an audit or risk assessment. An audit relating to the Disability Discrimination legislation is conducted at least once every three years. Risk assessments are undertaken at the request of the CEO. Finding of audits or risk assessments, together with suggested corrective and preventative actions, are initially presented to the CEO. The results are presented to the management team at their bi-annual Health and Safety Management meeting. The accountability for ensuring that such audits and risk assessments are conducted rests with the CEO. Risk assessments are undertaken on the use of the portable access ramp to the building.

Appraisal: there will be, at least every 12 months, an individual face to face interview to review the effectiveness of this company’s “disability symbol” activities. Additionally, this will be tailored for disabled employees, to focus on what further support is needed for them to perform to the potential of their ability. A summary note of all relevant information will be discussed at this company’s biannual Health & Safety Management meeting to decide on any needed actions including the ongoing development of awareness. The minutes of these meetings are available to all employees; such minutes will be used to record and monitor further actions.

Available employment: where a vacancy is to be internally advertised, and providing the minimum requirements are met, anyone with a disability will automatically be guaranteed an interview. Also, where an interview is not to be undertaken, they will form part of the field for consideration. However, not all internal vacancies are subject to interview as these may be filled as part of a developmental move for an individual. Where an employee becomes disables, or their disability changes, all reasonable adjustments will be considered to allow them to continue in their existing role. Where this is not possible, consideration will be given to employment within this company in another role, requiring a new contact of employment. If, after examining all the options, the company is not able to retain an employee, it will assist them in finding suitable alternative employment. This will be though allowing reasonable paid time to undertake job searching through the Jobcentre Plus disability employment adviser.

Review

This policy will be regularly reviewed, in the light of experience. Comments and contributions on the policy from staff, stakeholders and the public are welcome at any time

Statement of commitment and purpose

Klaspad LIMITED is committed to providing a high standard of communication to its shareholders and other investors to comply with its disclosure obligations under all markets in which it operates and that the market has available all information it reasonably requires to make informed assessments of Klaspad’s value and prospects. To achieve this, Klaspad has established policies and procedures which place accountability at a senior management level.

The purpose of this document is to describe the methods by which Klaspad communicates with its shareholders, with the objective of providing them with ready access to balanced and understandable information about Klaspad.

Communication with shareholders

Responsibility

The Company Secretary is responsible for communications and any other exchange on which its securities are listed, and compliance with its obligations under the various Listing Rules.

Methods of Communication

1. Periodic Reports

Annually, Klaspad produces the following reports to shareholders:

• The annual report comprising a review of operations, Corporate Governance Statement and the Financial Report for the year;
• A shareholder review which incorporates performance highlights, a review of operations and a five year financial history summary;
• The half year report containing a review of operations and financial update

Shareholders may elect to be sent each of these by mail or alternatively be notified by email when these are available at Klaspad main office on 23 Austin Friars, EC2N2QP, London, United Kingdom.

2. Announcements

Klaspad makes announcements to the shareholders of all material information that affects any of Klaspad’s activities in accordance with its continuous disclosure obligations and Klaspad’s policy. Information on the Company’s exploration, development and production activities is made on a regular basis including the following:

• commencement of significant operations in a new country
• cessation of any such operation; and
• notification of significant results or events.

3. Annual General Meetings

Klaspad holds an Annual General Meeting (AGM) normally in June of each year. The date, time and venue of the AGM is notified by the CEO.

The Notice of Meeting for the AGM is sent to shareholders with an explanatory memorandum providing information to shareholders to help them decide how they should vote on each item of business.

Klaspad welcomes and encourages shareholders to attend and participate at its AGM, either in person, by proxy or attorney or by other means adopted by the Board. At each AGM, the Chairman will allow a reasonable opportunity for members to ask questions of the Board. Members who are unable to attend the AGM will be able to view a webcast of the AGM (and of certain past AGMs).

The proceedings of AGMs including the formal addresses will be sent through email to all shareholders. Klaspad requires that its auditor attends each AGM so as to be available to answer any shareholder questions about the conduct of the audit and the preparation and content of the auditor’s reports.

4. Financial results

Following the full year and half year periods, Klaspad announces its results with a comprehensive report on the financial results and operations of the Company for the period.

5. Investor and analyst briefings

From time to time Klaspad conducts analysts and investor briefings. This may include formal presentations made by Klaspad at different companies or conferences. A record of all meetings and briefings with investors or analysts are kept, including confirmation that no new material information was disclosed.

6. Shareholder and investor queries

Shareholders with enquiries relating to their holding of Klaspad shares can contact Klaspad admin office. Contact details for the share registry and Investor Relations including email, telephone and facsimile contacts are provided in the Annual and Half Year reports to shareholders.

Klaspad is committed to responding to all shareholder and investor queries in a timely manner. Klaspad also offers shareholders the opportunity to register and receive the latest Klaspad reports and announcements by email.

Communication with students

Communications channels used to reach the student population include Klaspad system, social media, print and face-to-face

Departments/Schools have the responsibility to distribute important messages using methods that will most effectively target the relevant audience. The use of verbal communication and face-to-face interactions are encouraged, as are other channels aside from Klaspad and email.

This document assumes that staff are not solely responsible for communication between ourselves and our students. However, all student-facing staff should have access to appropriate customer service training.

We expect our students to keep their personal contact details up to date, and to know where to look for, and how to find, information relevant to them. However, in order to do so, academic departments and support services should ensure that key information is made available to prospective students prior to joining and that Welcome information covers the use of email, notice boards, information screens, and SMS text messaging, where appropriate.

All Klaspad communications should be clear, courteous, accurate, appropriate, and timely and, whatever the media chose, the content should be jargon-free, without the use of colloquialisms, unexplained acronyms or complex phraseology.

Email/ System Communication

Klaspad informs students that it is their responsibility to check their email account or login into the system at least twice a week during teaching periods.

Communication with the staff members

Different types of information will require different channels of communication and will be the responsibility of different people to disseminate. Here are the main categories of messages within the staff of the company:

1. Company's management and strategic direction

This includes information from senior management and committees regarding the overall management of Klaspad and its strategic direction. This may be updated on regular activities or committee decisions or it may be new information and activities that need to be communicated to staff in a timely and appropriate manner. This may involve communication of important information via management hierarchy.

2. Day-to-day work related information

This is the information staff members require to carry out their work day-to-day. It is the responsibility of individuals and their colleagues and line managers to communicate this information effectively.

3. Company notices

This is information that all staff or large groups of staff will benefit from and can be generated by any function within the company. Such information may be news items, forthcoming events, useful advice or more formal notices.

Staff communications with students

• All student enquiries must be taken seriously and dealt with in a polite professional manner.
• All students who email the Academy should usually expect to receive a reply within one or two working days. Staff should apportion up to an hour each day devoted to replying to student emails. If it is noticed that this hour is inadequate to deal with the volume of emails, then the Academy Director should be notified in order that the matter can be looked into and resolved.
• If out of the office for a working day, staff should set up an automatic email responder informing students of when their emails can expect to be answered.
• For repeat emails on the same topic a standard, but up to date, email response can be sent. This may be in the form of: "If your email is about... then..."
• Unreasonable student requests should be dealt with in a firm but fair way. Even though such an unreasonable request may be very common, it should be assumed in the first instance that each student is genuine, but unfamiliar with the unreasonableness of their request. It should not be assumed that they should already know such and such.
• If students become persistent then they should be reminded that their request has been / will be dealt with in due course, or that such a request is unreasonable due to such and such reason. Should they still persist, then they should politely be asked to desist as there is nothing more that can be done. If they are not satisfied with this, then they should be directed to email the Academy Director or student welfare officer to take the matter further.
• Students should not ever be promised anything, except in writing by a person authorised to do so. If a written communication to students already exists, then all staff are authorised to repeat the contents for students who are requesting clarification.
• Formal meetings with students should be recorded on a standard meeting minutes pro forma. Records should include: date, attendees, items discussed, actions agreed upon and outstanding matters. Meeting minutes should be copied to each attendee and the original filed with the senior administrator, either electronically or on paper.
• The Student Welfare Officer should be invited to all meetings related to students or policies, in order that they remain well informed of matters, to be able to swiftly respond to student enquiries.
• Emails should be addressed to only one recipient ("to"), but cc’d to all relevant people as appropriate.

Staff communications with other staff

• All staff should feel free to and be made welcome to, share ideas or suggestions with other staff on any matter. All suggestions should be heard without a guarantee of adoption. If the timing is inconvenient, then a later time should be scheduled to discuss the idea.
• Each week should usually include an all-staff meeting which has time scheduled to discuss concerns with student engagement/progress, either generally or specific cases. All staff should be engaged in such discussion so that all who interact with the students can be made aware of or raise any issues.
• Meetings should be recorded on a standard meeting minutes pro forma. Records should include date, attendees, items discussed, actions agreed upon and outstanding matters. Meeting minutes should be copied to each attendee and the original filed with the senior administrator, either electronically or on paper.
• Meeting minutes and other important documents should be added to the staff intranet system where they will be tagged according to the topic, type and date.

Decision making

• Decision making should never involve only one person.
• All decisions should come after consultation with those affected by the decision and after senior management approval.
• Meetings, where such decisions are discussed and taken, should be minute, and then filed with the senior administrator.
• Where possible such minutes should be made available on the staff intranet.
• Areas that particularly need attention include:

• Policy changes and new policies,
• Calendar dates, exam dates, assignment deadlines,
• External communications, including general emails to all students,
• Student interventions.
• New staff appointments.

Review

This policy will be regularly reviewed, in the light of experience. Comments and contributions on the policy from staff, stakeholders and the public are welcome at any time.

Introduction

"Corporate governance” refers to the oversight mechanisms and the way in which Klaspad is governed. The Board of Directors of Klaspad is elected by shareholders to supervise the management of Klaspad’s business and affairs with a view to enhancing long-term shareholder value. Corporate governance encompasses our processes and policies, how decisions are made and how the Klaspad deals with the various interests of, and relationships with, our many stakeholders, including shareholders, customers, employees and the broader community.

As a public institution, Klaspad recognises the need to adhere to best practices in corporate governance. Sound corporate governance policies and practices are important to the creation of shareholder value and maintaining the confidence of customers and investors alike.

Klaspad’s Corporate Governance Policies (the “Policies”) are designed to ensure the independence of the Board and its ability to effectively supervise management's operation of the company. The Policies are reviewed on an annual basis in the context of changing regulation and emerging best practices with a view to enhancing Klaspad's governance.

The Board of Directors

The Board's primary responsibility is to supervise the management of Klaspad’s business and affairs. The Board’s responsibility is one of stewardship. Senior management is accountable for implementing the Board’s decisions and responsible for directing Klaspad’s operations. The Board must provide effective governance over Klaspad’s affairs. In doing so it must strive to balance the interests of Klaspad’s diverse constituencies around the world, including its shareholders, customers, employees and the communities in which it operates. In all actions taken by the Board, the Directors are expected to exercise independent business judgment in what they reasonably believe to be in the best interests of Klaspad. In discharging that obligation, Directors may rely on the honesty and integrity of the CEO, its outside advisors and auditors.

Board Size

The Board has the authority to fix the number of Directors, which should be in the range of 2 to 10, with the flexibility to increase the number of members in order to accommodate an outstanding candidate or the Board's changing needs or circumstances. Candidates for the Board shall be and recommended to the Board for approval, in accordance with guidelines approved by the Board, taking into consideration the overall composition and diversity of the Board and the areas of expertise that new Board members can offer.

Term Limits

Klaspad's shareholders elect Directors at the annual meeting each year. Between meetings, the Board may appoint additional members. Term limits set out the maximum period of time that directors can stand for re-election, and do not provide guaranteed tenure. The Board believes that its term limits provide an appropriate balance between experience and fresh perspectives. The Board’s term limits, combined with director independence assessments and the Board evaluation process, enable the Board to confirm that effective and independent-minded directors are nominated for election and allow the Board to properly conduct its succession planning.

The Board has approved the following term limits:

• Directors elected or appointed to the Board at the time of incorporation, 2016, may serve on the Board until they attain the earlier of age 70 or the completion of a ten year term from the date of incorporation, provided that if such Director has not completed a ten year term at age 70, their term will be extended for additional years in order to complete a minimum ten year term.

Majority Voting in Director Elections

In an uncontested election of Directors of Klaspad, any nominee for Director who is not elected by at least a majority (50% + 1 vote) of the votes cast with respect to his or her election (a “Majority Withheld Vote”) shall immediately tender his or her resignation to the Chairman of the Board of Directors following Klaspad’s annual meeting.

The Board shall consider the resignation offer and shall recommend to the shareholders whether or not to accept it. The Board shall be expected to accept the resignation absent exceptional circumstances which would warrant the applicable Director to continue to serve on the Board. In considering whether or not to accept the resignation, the Board will consider all factors deemed relevant by members of such Board including, without limitation, the stated reasons why shareholders “withheld” votes from the election of that nominee, the length of service and the qualifications of the Director whose resignation has been tendered, such Director’s contributions to Klaspad.

Any Director who tenders his or her resignation pursuant to this Policy shall not participate in the Board meeting, if he or she is a member of that Board, to consider the decision to recommend to the shareholders whether his or her resignation shall be accepted. However, if each member of the Board received a Majority Withheld Vote in the same election, or a sufficient number of Board members such that Board no longer has a quorum, then the independent Directors shall appoint a committee amongst themselves to consider the resignation offers and recommend to the shareholders whether to accept them. However, if the only Directors who did not receive a Majority Withheld Vote in the same election, all Directors may participate in the determination of whether or not to accept the resignation offers.

In the event that any Director who received a Majority Withheld Vote does not tender his or her resignation in accordance with this Policy, he or she will not be re-nominated by the Board of Directors.

The Board may adopt such procedures as it sees fit to assist it in its determinations with respect to this Policy.

Board Composition – Qualifications and Considerations

One of the Board's most important responsibilities is to identify, evaluate and select candidates for the Board. The Directors and CEO are charged with reviewing the qualifications of potential Director candidates and making recommendations to the whole Board. The Board believes that its membership should be composed of highly qualified directors who demonstrate integrity and suitability for overseeing the management of Klaspad. Factors considered by the Board in its review of potential candidates include:

• prominence in business, institutions or professions;
• residency in and familiarity with the geographic regions where Klaspad carries on business;
• integrity, honesty and the ability to generate public confidence;
• demonstrated sound and independent business judgment;
• knowledge of and experience with It or educational institutions;
• risk management experience;
• knowledge and appreciation of public issues and familiarity with local, national and international affairs;
• the ability to devote sufficient time to Board work;
• the competencies and skills that the Board considers to be necessary for the Board, as a whole, to possess; and
• the competencies and skills that the Board considers each existing Director to possess.

The Board believes that its membership should be composed of highly qualified directors from diverse backgrounds, who reflect the qualities enumerated above. To support this composition as part of the Board to sound and effective corporate governance practices, the directors and CEO will, when identifying candidates to recommend for appointment or election to the Board:

• consider only candidates who are highly qualified based on their experience, expertise, perspectives, and personal skills and qualities;
• consider diversity criteria including gender, age, ethnicity and geographic background; and
• in addition to its own search, as and when appropriate from time to time, engage qualified independent external advisors to conduct a search for candidates who meet the Board’s expertise, skills and diversity criteria to help achieve its diversity goals.
• As part of its approach to Board diversity, the Board aspires to have at least 50% of its members be women.

Director Education

Directors shall be knowledgeable and informed about the business of Klaspad, the regulatory environment in which Klaspad and its subsidiaries operate, and their duties and responsibilities as Directors.

Klaspad shall assist Directors in their education about Klaspad and their duties and responsibilities as Directors. New Directors are provided with written information about Klaspad and their duties and responsibilities as Directors to assist them in their education and meet with the Chairman and Chief Executive Officer, and other Executive Officers, as required. All Directors have access to seminars and presentations on aspects of Klaspad’s business and operations and are provided with opportunities to visit domestic and international operations. Management regularly updates the Board on changing regulation and practices related to corporate governance.

Other Directorships

The Corporate Governance Committee will consider the following guidelines in determining whether a potential Director candidate is able to devote the requisite time and attention to Klaspad’s affairs, prior to the Board’s approval of the individual’s appointment or nomination for election. Existing Directors are also subject to these guidelines and prior to joining another public company board of directors, will be asked to review their existing board commitments with the Chair of the Corporate Governance Committee in order to assess whether the Director will be able to continue to devote sufficient time to Klaspad’s affairs.

The Corporate Governance Committee shall consider the following guidelines, which include Klaspad’s Board of Directors in the calculation, in reviewing public company directorships held by potential Director candidates or existing Directors:

• Directors who are CEOs or other senior executives of public companies should hold a maximum of two public company directorships, including membership on the board of the company at which the individual is CEO or a senior executive officer;
• Other Directors should hold a maximum of four public company directorships

The Board shall assess each Director’s or potential candidate’s other public company board commitments with reference to these guidelines. The Board shall also consider Directors’ private company directorships (held outside of their employment) in assessing whether the individual has the requisite time for Klaspad’s affairs. In doing so, the Board shall take into account the complexity of the other companies’ businesses, other roles a Director may undertake on such boards and the time commitment expected of the Director with respect to such boards. The Board has the discretion to determine, in certain circumstances, whether a Director candidate or existing Director is able to hold public company directorships which exceed these guidelines and will report decisions to the Board of Directors.

No Director of Klaspad shall sit on more than three audit committees of public company boards without the consent of the Board.

The Board also reviews interlocking board memberships to determine whether any common board memberships impair the ability of the involved Directors to exercise independent judgment as Klaspad Directors. No more than two Directors may sit on the same public company board without the consent of the Board.

No Director of Klaspad shall also be a member of the board of directors of an unaffiliated similar institution (which includes another learning system provider company or software company), without the prior approval of the Board and the confirmation of the CEO and Chairman and the Corporate Secretary.

Change in Directors' Principal Occupation

A Director who makes a change in principal occupation in relation to Klaspad must immediately offer to resign from the Board in order to give the Board the opportunity to review the impact of the change on the composition of the Board.

Board and Director Effectiveness

The Board shall conduct an annual review of its performance and may retain outside advisors to facilitate this annual review. Director peer evaluations shall be conducted every 2 years under the acceptance circumstance. The Board shall conduct an annual evaluation of its own performance. The results of these evaluations shall be summarised and presented to the Board which will then report on all these assessments to the shareholders. The Board may develop recommendations and/or an action plan, where determined necessary or desirable, to address issues raised as a result of such assessments, and will monitor the progress of the Board in addressing issues identified in the assessment process.

Attendance at Meetings

Directors are expected to attend meetings of Klaspad’s Shareholders, Board meetings on which they serve, and to spend the time needed to prepare for and to meet as frequently as necessary to properly discharge their responsibilities. Directors are required to attend a minimum of 75% of Board meetings held in a fiscal year. Those Directors who fail to meet this requirement must meet with the Chairman and CEO to discuss the reasons contributing to the Director’s attendance record and the Chairman will make a recommendation to the Board, as necessary, with respect to the Director’s continued role on the Board. In extraordinary circumstances where a significant number of special Board meetings are held in a fiscal year, the Chairman and CEO will consider extenuating circumstances that may prevent a Director from meeting the attendance requirement noted above and will report to the Board any exceptions to this requirement determined to be acceptable.

The Board recommends for shareholders approval a calendar of standard agenda items to be discussed at each meeting scheduled to be held over the course of the ensuing year. The Chairman and Chief Executive Officer, in consultation with the Corporate Secretary, shall establish the agenda for each Board meeting. Each Board member is free to suggest items for inclusion on the agenda or to raise subjects that are not on the agenda for that meeting. The non-management Directors shall meet in executive session at each Board meeting.

Non-Executive Chairman

The Board is committed to always having a Non-Executive Chairman. The Board believes this structure is appropriate to ensure independent Board leadership and to have effective Board oversight of management.

Access to Management and Subsidiary Directors

Directors shall have full and free access to senior management and other employees of Klaspad. Contact or meetings can be arranged for Directors through the Chief Executive Officer, the Corporate Secretary or directly by the Director. The Board welcomes regular attendance at each Board meeting by senior management of Klaspad.

Director Compensation

The Board determines the form and amount of Director compensation based on the recommendation of the Board following an annual review of Director compensation in the marketplace. Directors are required to hold a significant level of equity in Klaspad and as set out below, must take a significant portion of their compensation in shares or share equivalents.

Directors who are also officers of Klaspad are not compensated in their capacity as Directors.

Director Share Ownership

Directors are required to hold Klaspad common shares and/or director deferred share units (DDSUs) with a value of not less than £1000. This, however, will not be applicable to Non-Executive Directors although it is expected that they also take a minimum of £1000.00 worth of shares within one year of their joining the Board.

Executive Management

As the company grows the directors will endeavour to appoint various committees to form a strong executive management. The Human Resources Committee that shall review Klaspad’s senior level organisational structure and Klaspad’s management succession plan, including succession planning for Klaspad’s control function heads, at least once a year. The Risk Committee and Audit and Conduct Review Committee shall provide input to the Human Resources Committee on the succession planning for the control function heads that those Committees oversee.

The candidacy of all proposed Executive Officer appointments shall be reviewed by the Human Resources Committee and then submitted to the Board for approval. The Risk Committee may approve Executive Officer appointments in the period between Board meetings. All new senior management appointments shall be reported to the Board at least quarterly.

The Board shall review the mandates of Klaspad’s Executive Officers and job descriptions of the Chief Auditor, Chief Compliance and Regulatory Officer as established by the Human Resources Committee. These mandates shall define the duties, responsibilities and authority of the President and Chief Executive Officer and the other Executive Officers and control function heads of Klaspad. The Risk Committee shall also review the mandate for Klaspad’s Chief Risk Officer and the Audit and Conduct Review Committee shall review the mandate for Klaspad’s Chief Financial Officer and the job descriptions for the Chief Auditor, Chief Compliance and Regulatory Officer and Chief Anti-Money Laundering Officer, as set out in the Committees’ respective charters. The Board shall have the authority to dismiss and replace the Chief Executive Officer if required as defined in the Articles of Association of Klaspad

Review Executive Performance

The Human Resources Committee shall annually assess the performance of the President and Chief Executive Officer and all other Executive Officers. In addition to this assessment, the Risk Committee shall assess the effectiveness of the Chief Risk Officer and the Audit and Conduct Review Committee shall assess the effectiveness of the Chief Financial Officer, Chief Auditor, Chief Compliance and Regulatory Officer and Chief Anti-Money Laundering Officer and the Committees shall convey their views on these assessments to the Human Resources Committee and management, in accordance with the Committees’ Charters. The Board Committees shall consider regulatory findings as part of their reviews of management.

Review Compensation

The Human Resources Committee shall review and recommend to the Board for approval all material employee compensation and benefits plans and programs, including Klaspad’s employee pension plan. This review will include an assessment of whether Klaspad’s compensation plans are consistent with the sustainable achievement of Klaspad’s business objectives, the prudent management of its operations and the risks to which it is exposed, and will look for adherence to Klaspad’s processes, policies, procedures and controls. The Human Resources Committee shall review and the Board shall approve the compensation for all Executive Officers, the Chief Auditor, Chief Compliance and Regulatory Officer and Chief Anti-Money Laundering Officer on an annual basis.

Oversee Strategic Management

The Board shall establish the business objectives of Klaspad, consider and approve Klaspad’s business strategy and its business plans for significant operations, and review those things at least once a year to ensure that the strategic plans remain appropriate and prudent in light of Klaspad’s current and anticipated business and economic environment, resources, risks and results. The Board shall obtain reasonable assurance, on a regular basis, that there is an ongoing and effective process in place for ensuring appropriate strategic management of Klaspad.

The Board shall frequently evaluate Klaspad’s actual operating and financial results against forecast results, in light of Klaspad’s business objectives, business strategy, and business plans.

Oversee Risk Management and Risk Management Function

A sound system of risk management is critical to the profitability and ongoing viability of Klaspad. Directors must understand the significant risks to which Klaspad is exposed. The Board shall establish appropriate and prudent risk management policies. The Risk Committee shall oversee and have regard to the independence of Klaspad’s risk management function by annually reviewing and approving: the mandate of the Chief Risk Officer and the Charter of the Global Risk Management Department; sufficient resources and budget for the Global Risk Management Department; and the organizational structure of the Global Risk Management Department. The Committee shall assess the Global Risk Management Department’s effectiveness and shall also periodically request independent reviews of the Global Risk Management Department and review the results of such reviews prior to reporting to the Board.

The appointment and removal of Klaspad’s Chief Risk Officer shall be approved by the Risk Committee. The Risk Committee is responsible for overseeing that the Global Risk Management Department has unfettered access and a functional reporting line to the Committee.

Disclosure and Communications

Klaspad is committed to providing timely, accurate and balanced disclosure of all material information about Klaspad and to providing fair and equal access to such information.

The Board requires that management has processes in place to support its policy of full, true, plain and timely disclosure of financial results, significant developments and other material information to appropriate stakeholders such as shareholders, regulators, employees, rating agencies, analysts and stock exchanges as and when applicable.

Introduction

Klaspad has produced this simple contents list for company annual reports, to assist those preparing reports. The primary purpose of the annual report is to explain to shareholders and other investors how the company has performed over the past year, and how it generates and/ or preserves value over the longer-term. The following attributes are considered hallmarks of good practice in the preparation of annual reviews to shareholders.

Consistent

Year-to-year, the format should be consistent so that shareholders are able to make easy comparisons with reports from prior periods. However, that does not mean reporting and business developments, which could improve the effectiveness of the reporting format, should be overlooked for the sake of consistency with prior year reports.

Straightforward

The annual review should be written on the assumption that shareholders are not industry or finance specialists.

Succinct

Narratives should be concise and to-the-point, although this does not mean leaving out important material in order to meet any specific length limit.

Clear

The report should be written in plain English with a simple layout so that key messages are readily identified. Although this guide is focused on non-statutory annual reporting, the principles are equally relevant to other communications with shareholders such as half-yearly reviews and sustainability reports.

Annual report contents

The annual report and accounts, taken as a whole, should be fair, balanced and understandable and provide the information necessary for shareholders to assess the company’s position and performance, business model and strategy.

1. Highlights

• Financial highlights
• Summary of objectives, strategy and business model, KPIs, strategic risk management

2. Strategic report

The purpose of the strategic report is to inform members and help them assess how the directors have performed their duty to promote the success of the company. It must be approved by the board, signed separately and filed with the Registrar of Companies. The strategic report should include:

• a fair, balanced, comprehensive and understandable review, consistent with the size and complexity of the business, including an analysis of:
  • the development and performance of the company’s business during the financial year
  • the position of the company at the end of the year and
  • Key Performance Indicators (KPIs): both financial and non-financial
• a description of the principal risks and uncertainties facing the company and a report on the risks including:
  • confirmation by the directors that they have carried out a robust assessment of the principal risks facing the company, including those that would threaten its business model, future performance, solvency or liquidity; a description of those risk and explanation of how they are being managed or mitigated
  • an explanation of how the directors have assessed the prospects of the company, over what period they have done so and why they consider that period to be appropriate; and whether they have a reasonable expectation that the company will be able to continue in operation and meet its liabilities as they fall due over the period of their assessment, drawing attention to any qualifications or assumptions as necessary (otherwise referred to as the viability statement)
  • a report on the board’s review of the effectiveness of the company’s risk management and internal control systems
• a description of the company’s:
  • principal objectives
  • strategy and
  • business model and linkage to, and discussion of, KPIs
• analysis of the development and performance of the business in the financial year and of its position at the end of the year
• trends and factors likely to affect the future development, performance or position of the business, to the extent necessary for an understanding of the business
• a statement by the directors of whether they considered it appropriate to adopt the going concern basis of accounting in preparing the financial statements, identifying any material uncertainties to the company’s ability to continue to do so over a period of at least twelve months from the date of approval of the financial statements
• if applicable, details of strategically important matters on sustainability, ethics, values and/or corporate social responsibility
• information on environmental matters; employees; and social, community and human rights issues, to the extent necessary for an understanding of the development, performance or position of the company’s business, or a statement that the information has not been included, including which of the three types of information has not been included
• information as at the year-end about the gender diversity of
  • directors
  • senior managers and
  • employees, in the group as a whole
• any matter that is considered to be of strategic importance, which is also required to be included in the directors’ report
• any additional explanations of amounts included in the company’s annual accounts Supplementary material to be provided with the strategic report when it is used as a replacement to summary financial statements:
• a statement that the strategic report forms part of the annual report and information on how recipients can obtain a copy of the full annual report
• a statement as to whether the auditor’s report was qualified or unqualified, and further information if the auditor’s report was qualified
• a copy of the section of the directors’ remuneration report that sets out the single figure total in respect of directors’ pay

a. Chairman’s statement

• results and dividend
• overview of trading and the business including management, succession planning, diversity and values
• governance overview including the impact of governance and risk management processes
• comments on corporate responsibility, sustainability and communities
• commentary on markets and the environment
• outlook statement

b. Chief executive’s review

• commentary on markets and the environment
• detailed commentary on the business
• commentary on KPIs
• commentary on the management of assets
• outlook statement

c. Chief financial officer’s review

If companies wish to include a CFO review this might include commentary on the financial results, dividends, balance sheet, capital position and going concern.

d. Directors’ report

• the names of all directors during the financial year
• the amount of dividend, if any, recommended by the directors
• a statement of any qualifying indemnity provisions for the benefit of any directors (or directors of associated companies) during the financial year
• a statement confirming that all relevant audit information has been provided to the company’s auditor
• if applicable, a statement that the strategic report includes information required by the 2008 Regulations to be included, and an indication as to which information this applies
• a report on the annual quantity of greenhouse gas emissions from activities for which the company is responsible
• if applicable, a prominent statement that advantage has been taken of the small companies’ exemption
• information on political donations totalling in excess of £2,000
• unless not material, financial risk management objectives and policies and exposure to price, credit, liquidity and cash flow risk
• details of any post year-end important events affecting the company or group
• likely future developments in the business, research and development and details of branches outside the UK
• information on the acquisition of own shares
• the company’s policy on employment of disabled persons
• a description of actions in relation to employees
• information on company’s capital and holders of securities and agreements in relation to change of control/takeover
• going concern statement (if not included in the strategic report)
• directors’ interests
• share capital
• voting rights
• disclosure of major shareholders (holding over 3%)
• directors’ responsibilities statement
• auditor’s independence statement

3. Report on sustainability, ethics, values, and/or corporate and social responsibility

Summary of information contained on the company’s website or in a separate report.

4. Board of directors and secretary

Profiles of the board of directors and the secretary and a link to the profiles on the company’s website.

5. Corporate governance report

a. Corporate governance statement

• introduction by chairman including governance overview and diversity statement
• statement of compliance with UK Corporate Governance Code, or other applicable code, and meaningful explanations of any non-compliance
• information on governance/risk management structures
• report on board responsibilities, activities, attendance etc.
• report on board evaluation and outcomes
• report on each committee including a letter from the committee chairman, committee responsibilities, activities, attendance etc, and reporting by the audit committee on judgments taken on significant issues, their assessment of the performance of the external audit process; and impairment assumptions.

b. Directors’ remuneration report (for quoted companies)

• statement by the chairman of remuneration committee including key messages on remuneration, showing a clear link to strategy, the context of decisions taken and major changes during the year
• the single total figure of remuneration for each director set out in the required table and with required comparator figures (except in the first year), explanatory notes and graphs
• details of any payments to past directors
• where the directors’ remuneration policy is not being put to a resolution at the AGM, performance targets for the financial year in which the meeting is held (unless statement of performance targets was included in the last approved policy), subject to any matter which, if disclosed, would in the opinion of the directors be commercially sensitive to the company
• details of remuneration committee including members, providers of services, fees paid and assessment of independence
• a statement of voting on remuneration report and remuneration policy in the previous year
• a separate section on remuneration policy including the required statements; the required table on future policy and explanations of assumptions used; policy on the loss of office payments; statement of consideration of pay and employment conditions of employees; and a statement on whether any shareholder views have been taken into account
• Supplementary information and explanations as necessary

6. Independent auditors’ report

7. Financial statements

Details of the financial statements are not covered in this list of contents but this section of the annual report should include:

• accounting policies
• consolidated income statement
• consolidated statement of comprehensive income
• statements of financial position (consolidated and company)
• consolidated statement of changes in equity
• company statement of changes in equity
• statement of cash flows (consolidated and company)
• notes to the financial statements
• five year financial summary

8. Shareholder information

9. Financial calendar

10. Company information

11. Registrar and corporate adviser

Review

This policy will be regularly reviewed, in the light of experience. Comments and contributions on the policy from staff, stakeholders and the public are welcome at any time.

Klaspad will aspire to invest at least 50% of its post-tax profits in further technology innovation and growing its market share for the first three years. Earnings will be retained to fund growth.

Public Offering Policy

Klaspad may seek a public listing when market conditions are suitable and the company has proven trading performance with good future prospect and plans. Klaspad believes that this is unlikely to happen before 5 years of successful trading.

Prior to financing the subscription for a new share issue, Klaspad will conduct a thorough analysis covering, among other things, the following:

• The potential impact of the capital
• The likely market response to the issue
• The overall sentiment in the stock market; and
• The competence, reliability and reputation of the sponsor(s), lead manager(s), and underwriter(s)

Klaspad is expected to have general policies and guidelines approved by the Board or CEO to govern the criteria for financing the subscription for new share issues. Deviations from such general policies and guidelines should have the approval of the appropriate authority.

Introduction

The initial public offering (IPO) requires a great deal of effort, cost and management focus. The preparation and execution of an IPO require the company, working closely with legal counsel, auditors and underwriters, to identify, analyse and resolve a myriad of legal, accounting and business issues. General considerations that an IPO candidate should evaluate to determine whether it is prepared for an IPO to include:

• The company’s profitability, growth prospects, financial condition and results of operations;
• The company’s visibility into, and the predictability of, its future financial results;
• The company’s competitors and competitive position, and the status of the company’s competitive barriers to entry;
• Risk factors relevant to the company, its industry and the public markets generally;
• The status of the public markets generally and market conditions for the particular company’s industry; and
• Investor relations demands, including the need to build and preserve credibility with analysts, the financial press, regulators, institutional stockholders and other players in the capital markets;

There are a number of other considerations that Klaspad should evaluate before contemplating an IPO, including restrictions on publicity before and during the offering; selection of underwriters; disclosure of related-party transactions; disclosure of executive compensation; prohibition on loans to directors and officers; structure of the board and board committees; adequacy of disclosure practices and procedures; ethics and conduct codes and procedures; accounting and corporate law matters; listing on a stock exchange. Klaspad believes that they will need a period of 3 to 5 years before seeking public offering. Until that time, Klaspad will make sure that they are fully prepared with all the legal requirements.

Review

This policy will be regularly reviewed, in the light of experience. Comments and contributions on the policy from staff, stakeholders and the public are welcome at any time.

Purpose

Set out our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption; and Provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues.

Bribery and corruption are punishable for individuals by imprisonment and if we are found to have taken part in corruption we could face substantial fines as well as property seizure, be excluded from tendering for public contracts and face damage to our reputation. We, therefore, take our legal responsibilities very seriously. In this policy, the third party means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

Introduction

Klaspad's policy is to conduct all of our business in an honest and ethical manner. We take a zero tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.

We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by the laws of the UK including the UK Bribery Act 2010 in respect of our conduct both at home and abroad.

Who is covered by the policy?

This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as workers in this policy).

What is bribery?

A bribe is an inducement or reward offered, promised or provided to gain any commercial, contractual, regulatory or personal advantage.

Examples:

a. Offering a bribe

You offer potential client tickets to a major sporting event, but only if they agree to do business with us. This would be an offence as you are making the offer to gain a commercial and contractual advantage. We may also be found to have committed an offence because the offer has been made to obtain business for us. It may also be an offence for the potential client to accept your offer.

b. Receiving a bribe

A supplier gives your nephew a job but makes it clear that in return they expect you to use your influence in our organisation to ensure we continue to do business with them. It is an offence for a supplier to make such an offer. It would be an offence for you to accept the offer as you would be doing so to gain a personal advantage.

c. Bribing a foreign official

You arrange for the business to pay an additional payment to a foreign official to speed up an administrative process, such as clearing our goods through customs.

The offence of bribing a foreign public official has been committed as soon as the offer is made. This is because it is made to gain a business advantage for us. We may also be found to have committed an offence.

d. Gifts and hospitality

This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties. The giving or receipt of gifts is not prohibited if the following requirements are met:

• it is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
• it complies with local law;
• it is given in Storm's name, not in your name;
• it does not include cash or a cash equivalent (such as gift certificates or vouchers);
• it is appropriate in the circumstances. For example, in many places it is customary for small gifts to be given at Christmas time;
• taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time; and
• it is given openly, not secretly.

Furthermore, gifts should not be offered to, or accepted from, government officials or representatives, or politicians or political parties, without the prior approval of a member of the Senior Management Team. We appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.

Why is not acceptable?

It is not acceptable for you (or someone on your behalf) to:

give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;

give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to "facilitate" or expedite a routine procedure; accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them;

accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return;

threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or engage in any activity that might lead to a breach of this policy.

Facilitation payments and kickbacks

We do not make, and will not accept, facilitation payments or "kickbacks" of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official. They are not commonly paid in the UK but are common in some other jurisdictions.

If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with a member of the Senior Management Team.

Kickbacks are typically payments made in return for a business favour or advantage. All workers must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.

Donations

We do not make contributions to political parties. We only make charitable donations that are legal and ethical under local laws and practices. No donation must be offered or made without the prior approval of a member of the CEO.

Management team Responsibilities

You must ensure that you read, understand and comply with this policy.

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify a member of the Senior Management Team as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. For example, if a client or potential client offers you something to gain a business advantage with us, or indicates to you that a gift or payment is required to secure their business.

Record-keeping

We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

You must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review.

You must ensure all expenses claims relating to hospitality, gifts or expenses incurred by third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure.

All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept "off-book" to facilitate or conceal improper payments.

How to raise a concern

You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised with a member of the Senior Management Team. Concerns should be reported by following the procedure set out in our Whistleblowing Policy.

What to do if you are a victim of bribery or corruption

It is important that you tell a member of the Senior Management Team as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.

Protection

Workers who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. We 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 refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

If you believe that you have suffered any such treatment, you should inform a member of the Senior Management Team immediately. If the matter is not remedied, and you are an employee, you should raise it formally using the Grievance.

Procedure

Training on this policy forms part of the induction process for all new workers. All existing workers will receive regular, relevant training on how to implement and adhere to this policy.

Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.

Who is responsible for the policy?

The CEO has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

The CEI has primary responsibility for implementing this policy, and for monitoring its use and effectiveness and dealing with any queries on its interpretation. Management at all levels is responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it.

Monitoring and review

The CEO will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.

All workers are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.

Workers are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the CEO.

This policy does not form part of any employee's contract of employment and it may be amended at any time.

Schedule

The following is a list of possible red flags that may arise during the course of you working for us and which may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only.

If you encounter any of these red flags while working for us, you must report them promptly to a member of the Senior Management Team or using the procedure set out in the Whistleblowing Policy:

• you become aware that a third party engages in, or has been accused of engaging in, improper business practices;
• you learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a "special relationship" with foreign government officials;
• a third party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function or process for us;
• a third party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;
• a third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business;
• a third party requests an unexpected additional fee or commission to "facilitate" a service;
• a third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services;
• a third party requests that a payment is made to "overlook" potential legal violations;
• a third party requests that you provide employment or some other advantage to a friend or relative;
• you receive an invoice from a third party that appears to be non-standard or customised;
• a third party insists on the use of side letters or refuses to put terms agreed in writing;
• you notice that we have been invoiced for a commission or fee payment that appears large given the service stated to have been provided;
• a third party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us; or
• you are offered an unusually generous gift or offered lavish hospitality by a third party.

Review

This policy will be regularly reviewed, in the light of experience. Comments and contributions on the policy from staff, stakeholders and the public are welcome at any time.

Klaspad LIMITED welcomes feedback from students who are using Klaspad system because it is chiefly by listening to students’ views that we can monitor the service we are providing and ensure that we continue to provide students with the high level of service that they expect, but also better enable us to improve that service.

• Students are encouraged to let us know what we are doing particularly well or make suggestions about how to improve our system by informing us through the feedback option on the student’s dashboard.

Student Concerns

• If a student has a concern about his/ her individual experience, they are encouraged to raise the matter with the relevant member of staff immediately.
• If, however, the relevant member of staff cannot resolve the issue to the student’s satisfaction the issue will then be referred by that member of staff to the administrator. It is anticipated that most student issues/concerns will be resolved at this stage.
• The procedure for addressing student concerns as distinct from complaints is, in essence, informal but with an emphasis upon prompt resolution of the matter in question. While it is recognised that matters of concern may involve exchanges of correspondence, what distinguishes this procedure from the formal complaints procedure is that the student is not making a complaint and the formal procedure for handling a complaint by definition does not apply.

Student Complaints

If in the student’s view, a complaint cannot be resolved informally then he or she may make a formal complaint within a reasonable period of time.

• Complete a Complaints Form setting out clearly the nature and origin of the complaint detailing what steps, if any, have been taken to resolve it informally and explaining why the outcome of the informal procedure is not considered appropriate or satisfactory. Complaints Forms can be obtained from the administrator. The completed form should be returned to the administrator.
• The administrator will acknowledge the complaint within five working days of receipt and will let the student know who will be dealing with the complaint.
• The person dealing with the complaint will, within two weeks of the referral from the administrator, contact the complainant and indicate what action they plan to take, and the date by which they expect any investigation to be complete. If the investigation cannot be completed by the expected date, the person dealing with the complaint will advise the student of the delay.
• The person dealing with the complaint will respond in writing to the complainant when any investigation is complete with details of the findings, and if the complaint is upheld will indicate what the outcome will be.
• The response to the complaint will be copied to the administrator who will maintain a central record of complaints.
• If the administrator is the subject of the complaint, then a student should follow the same procedure except that the form should instead be sent to the management team.

Review

This policy will be regularly reviewed, in the light of experience. Comments and contributions on the policy from staff, stakeholders and the public are welcome at any time.

The purpose of this policy is to describe the basis upon which Klaspad LIMITED can avail themselves of the intellectual property rights conferred upon them to operate the system.

Intellectual Property Rights

• Klaspad LIMITED agrees not to use any Courses or other IPR other than as expressly permitted by the relevant Agreements.
• Klaspad LIMITED recognises and agrees that all Intellectual Property Rights in and in relation to any work and materials created by any other party in relation to the Course(s) (including without limitation updates and adaptations to Course(s) materials) belongs to any other party, unless the Parties agree otherwise in writing.
• Klaspad LIMITED must not knowingly cause or permit anything to occur which may damage or endanger any of the Course(s) IPR or any other Intellectual Property Rights owned or used by any other party.
• Klaspad LIMITED is required to promptly and fully notify any other party of any actual, threatened or suspected infringement of any such Course(s) IPR or other Intellectual Property Rights which comes to its notice, and Klaspad LIMITED must do all such things as may be reasonably required to assist the latter in taking or resisting any proceedings in relation to any such infringement or claim.
• Klaspad LIMITED is required to bring the terms of this policy to the attention of all campus staff and to use their best endeavours to ensure that no member of staff (whether full time or part time) or consultant etc acts in breach of it intentionally or unintentionally. This includes but is not restricted to explaining the policy to all relevant staff, carrying out any necessary training and including appropriate clauses in contracts of employment or engagement etc.
• Any other party agrees that Klaspad LIMITED has developed the product over a long period and as such all IP rights will remain the property and copyright of Klaspad LIMITED.

Review

This policy will be regularly reviewed, in the light of experience. Comments and contributions on the policy from staff, stakeholders and the public are welcome at any time.

The aims of Klaspad Academy staff development policy are to:

• help you develop the skills and give you the knowledge necessary to do the jobs for which you have been recruited
• help you develop the skills and give you the knowledge required in other jobs in the Academy, so that flexibility may be achieved at all levels in the Academy
• equip you for promotion, should the possibility arise
• increase the effectiveness of everyone in the Academy, and therefore of the Academy as a whole.

Investment

The Academy will invest time and resources in the development of its staff, both full and part-time.

• All new staff will receive a thorough induction into the culture and practices of the Academy.
• Senior management will identify opportunities for staff development, to be offered to those who are most appropriately likely to benefit from them.
• Each year staff should spend at least two full days on personal development, or more if there is sufficient justification to do so.
• As awarding body policies and procedures are updated, relevant staff will be invited to attend update or refresher sessions, run either internally or externally.
• Staff are to be supported in maintaining their continuous professional development (CPD) portfolio and undertake relevant standardisation tasks accordingly.
• Staff are encouraged to join and upon request will be supported in becoming members of the Institute for Learning.
• Awarding body standardisation exercises will be conducted as required and any extra training or support will be arranged for staff who may require this. Meetings to discuss such standardisation matters are part of the regular Academic Committee meeting cycle, as detailed in the Staff Communications Policy.
• Staff are expected to, and therefore supported in, research of their specialist fields of expertise to stay abreast of recent developments.

Appraisal

Members of staff will be appraised by their manager, who will complete a formal annual appraisal which will be based upon a discussion with the employee. Employees will have the opportunity to air their views, record any comments and discuss plans for their development.

Promotion

All promotions are made solely on the basis of individual merit, and all suitable candidates will be considered regardless of their sex, race, religion, disability, sexual orientation or age. An individual’s potential for promotion is assessed by considering many aspects of their past, current performance and future capabilities.

This policy is based upon a sample produced by ACAS

Staff Grievance Procedure

• Dealing with grievances informally
  If you have a grievance or complaint to do with your work or the people you work with, which cannot be resolved directly, you should, wherever possible, start by talking it over with your manager. You may be able to agree a solution informally between you.
• Formal grievance
  If the matter is serious and/or you wish to raise the matter formally you should set out the grievance in writing to your manager. You should stick to the facts and avoid language that is insulting or abusive. Where your grievance is against your manager and you feel unable to approach him or her you should talk to another manager or the owner.
• Grievance hearing
  Your manager will call you to a meeting, normally within five days, to discuss your grievance. You have the right to be accompanied by a colleague or trade union representative at this meeting if you make a reasonable request. After the meeting the manager will give you a decision in writing, normally within 24 hours.
• Appeal
  If you are unhappy with your manager’s decision and you wish to appeal you should let your manager know. You will be invited to an appeal meeting, normally within five days, and your appeal will be heard by a more senior manager (or the Academy owner). You have the right to be accompanied by a colleague or trade union representative at this meeting if you make a reasonable request. After the meeting the manager (or owner) will give you a decision, normally within 24 hours. The manager’s (or owner’s) decision is final.

This policy is based upon a sample produced by ACAS

Policy statement

We are committed to improving the health, wellbeing and attendance of all employees. We value the contribution our employees make to our success. When any employee is unable to be at work for any reason, we miss that contribution. This absence policy explains:

• what we expect from managers and employees when handling absence
• how we will work to reduce levels of absence to no more than five days per employee per year. We welcome the continued involvement of employees in implementing this policy.

Key principles

The Academy’s absence policy is based on the following principles:

• As a responsible employer we undertake to provide payments to employees who are unable to attend work due to sickness.
• Regular, punctual attendance is an implied term of every employee’s contract of employment – we ask each employee to take responsibility for achieving and maintaining good attendance.
• We will support employees who have genuine grounds for absence for whatever reason. This support includes:
  • 'special leave' for necessary absences not caused by sickness
  • a flexible approach to the taking of annual leave
  • access to counsellors where necessary
  • rehabilitation programmes in cases of long-term sickness absence
• We will consider any advice given by the employee’s GP on a ‘Statement of Fitness for Work’. If the GP advises that an employee ‘may be fit for work’ we will discuss with the employee how we can help them get back to work – for example, on flexible hours, or altered duties.
• We will use an occupational health adviser, where appropriate, to:
  • help identify the nature of an employee’s illness
  • advise the employee and their manager on the best way to improve the employee’s health and wellbeing.
• We respect the confidentiality of all information relating to an employee’s sickness. This policy will be implemented in line with all data protection legislation and the Access to Medical Records Act 1988.
• The Academy’s disciplinary procedures will be used if an explanation for absence is not forthcoming or is not thought to be satisfactory.

Notification of absence

If an employee is going to be absent from work they should communicate this to their manager or deputy within an hour of their normal start time. They should also:

• give a clear indication of the nature of the illness and
• a likely return date.

The manager will check with employees if there is any information they need about their current work. If the employee does not contact their manager by the required time the manager will attempt to contact the employee at home.

An employee may not always feel able to discuss their medical problems with their line manager. Managers will be sensitive to individual concerns and make alternative arrangements, where appropriate. For example, an employee may prefer to discuss health problems with a person of the same sex.

Evidence of incapacity

Employees can use the Academy self-certification arrangements for the first five days absence. Thereafter a letter from a GP in the form of a ‘Statement of Fitness for Work’ is required to cover every subsequent day. If absence is likely to be protracted, i.e. more than four weeks continuously, there is a shared responsibility for the Academy and the employee to maintain contact at agreed intervals.

‘May be fit for some work’

If the GP advises on the Statement of Fitness for Work that an employee ‘may be fit for work’ we will discuss with the employee ways of helping them get back to work. This might mean talking about a phased return to work or amended duties.

Return to work discussions

Managers will discuss absences with employees when they return to work to establish:

• the reason for, and cause of absence
• anything the manager or the Academy can do to help
• that the employee is fit to return to work.

If an employee’s GP has advised that they ‘may be fit for work’ the return to work discussion can also be used to agree in detail how their return to work might work best in practice. A more formal review will be triggered by:

• frequent short-term absences
• long-term absence.

This review will look at any further action required to improve the employee’s attendance and wellbeing. These trigger points are set by line managers and are available upon request.

Absence due to disability/maternity

Absences relating to the disability of an employee or to pregnancy will be kept separate from sickness absence records. We refer employees to our Equal Opportunity Policy.

This policy is adapted from a sample policy produced by ACAS

Fraud is a serious potential problem for any institution, but particularly serious when dealing with public funding. The guidelines set out below aim to identify instances of suspected fraud early, so that they can be dealt with in a timely manner.

Fraud must not be accepted at any level, whether financial or academic. The Academy has a duty to promote the highest standards at all times, so any action or suggestion that fraud can be tolerated is absolutely inappropriate and will invoke the Staff Disciplinary Policy Staff Disciplinary Policy.

The senior management committee is responsible for the prevention, detection and investigation of irregularities, including fraud.

Fraud is primarily prevented through adhering to the Academy’s various adopted policies. Regular and ad-hoc audits of Academy functions also serve as a deterrent and an early warning of possible irregularities.

Matters of academic integrity, from admissions, to programme delivery, to certification are the remit of the Academy Registrar. An annual audit of academic functions in the Academy will be conducted by the Registrar, as well as ad-hoc audits as often as the Registrar deems necessary. All emails, files (paper and electronic) and database record shall be made available to the Registrar during such audits.

Matters of financial irregularity, and all other irregularities in all areas of the Academy finances are the remit of the Academy Director. An annual audit of financial functions in the Academy will be conducted by, or arranged by, the Academy Director, as well as ad-hoc audits as often as the Academy Director deems necessary. All emails, files (paper and electronic) and database record shall be made available to the Academy Director during such audits.

Staff and students of the Academy are encouraged to be vigilant when applying the Academy policies at all times. They are also encouraged to raise any concerns that they may have in writing in confidence to the Academy Director in the first instance, or the Academy owner, if the concerns are regarding the Academy Director. Staff should be made aware of this policy as part of their induction programme. Students should be made aware of the seriousness with which the Academy views irregularities and fraud, as well as the mechanism for raising concerns.

Persons identifying irregularities will not be adversely affected as a result of ‘whistle blowing’ or identifying. If, however, upon investigation they are implicated in the irregularity, then they may face appropriate disciplinary measures.

An individual gaining or seeking to gain inappropriate access to files, records or computer systems, which are not ordinarily part of that individual’s role, will be viewed as a potential instance of irregularity and will invoke an investigation, headed by the appropriate senior management team member, as identified above. At any point in time the Academy Director can invite an external auditor to conduct a limited or full audit of Academy functions.

Purpose and scope

The Academy aims to encourage improvement in individual conduct or performance. This policy sets out the actions which will be taken when disciplinary rules are breached.

Principles

• The policy is designed to establish the facts quickly and to deal consistently with disciplinary issues. No disciplinary action will be taken until the matter has been fully investigated.
• At every stage employees will be informed in writing of what is alleged and have the opportunity to state their case at a disciplinary meeting and be represented or accompanied, if they wish, by a trade union representative or a work colleague.
• An employee has the right to appeal against any disciplinary penalty.

The Procedure

• Stage 1 – first warning
  If conduct or performance is unsatisfactory, the employee will be given a written warning or performance note. Such warnings will be recorded, but disregarded after six months of satisfactory service. The employee will also be informed that a final written warning may be considered if there is no sustained satisfactory improvement or change. Where the first offence is sufficiently serious, for example because it is having, or is likely to have, a serious harmful effect on the Academy, it may be justifiable to move directly to a final written warning.
• Stage 2 – final written warning
  If the offence is serious, or there is no improvement in standards, or if a further offence of a similar kind occurs, a final written warning will be given which will include the reason for the warning and a note that if no improvement results within two months, action at Stage 3 will be taken.
• Stage 3 – dismissal or action short of dismissal
  If the conduct or performance has failed to improve, the employee may suffer demotion, disciplinary transfer, loss of seniority or dismissal.

Gross misconduct

If, after investigation, it is confirmed that an employee has committed an offence of the following nature (the list is not exhaustive), the normal consequence will be dismissal without notice or payment in lieu of notice:

• theft or fraud
• physical violence or bullying
• deliberate and serious damage to property
• serious misuse of an Academy’s property or name
• deliberately accessing internet sites containing pornographic, offensive or obscene material
• serious insubordination
• unlawful discrimination or harassment
• bringing the Academy into serious disrepute
• serious incapability at work brought on by alcohol or illegal drugs
• causing loss, damage or injury through serious negligence
• a serious breach of health and safety rules
• a serious breach of awarding body expectations or rules
• a serious breach of confidence.

While the alleged gross misconduct is being investigated, the employee may be suspended, during which time he or she will be paid their normal pay rate. Any decision to dismiss will be taken by the employer only after full investigation.

Appeals

An employee who wishes to appeal against any disciplinary decision must do so to the Academy Academy Director within five working days. The employer will hear the appeal and decide the case as impartially as possible

This policy is based upon a sample produced by ACAS