Ashford Education Limited 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 Ashford Education Limited, 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 Ashford Education Limited 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 Ashford Education Limited's code of ethics or suspected violations of law or regulations that govern our operations.

No Retaliation

It is contrary to the values of Ashford Education Limited 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 Ashford Education Limited. 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

Ashford Education Limited 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 Ashford Education Limited'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

Ashford Education Limited'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

Ashford Education Limited'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

Ashford Education Limited'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

Ashford Education Limited 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, Ashford Education Limited 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

Ashford Education Limited 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

Ashford Education Limited 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 and Task Risk Assessment Form details (tables and calculation method) are available on request. Contact contact@ashfordeducationlimited.com for full documentation.

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.

Ashford Education Limited 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 Ashford Education Limited 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 Ashford Education Limited 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 Ashford Education Limited 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

Ashford Education Limited 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 Ashford Education Limited 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 Ashford Education Limited 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: Accidents and incidents involving the risk of blood borne infection (sharps injuries, needle injuries, contamination of cuts or abrasions, mucous membrane contact), cleaning up spillages of blood/vomit/excreta, urine spillages, and safe disposal of contaminated sharps are covered by detailed infection control procedures. Full details are available from Ashford Education Limited on request.

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 Ashford Education Limited 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 Ashford Education Limited 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.

Ashford Education Limited 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.

Ashford Education Limited 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. Ashford Education Limited will take all reasonable steps to ensure that applicants may be safely entrusted with the duties of their position.

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

Ashford Education Limited is committed to providing a work environment that is free from harassment and discrimination. All recruitment and selection procedures and decisions will reflect Ashford Education Limited'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 and are given continuous support and guidance.

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

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, Ashford Education Limited will advertise all vacancies internally. Exceptions may occur when the position is of such a specialised nature that appropriate skills are not available within the organisation, or there is a need to make a direct appointment or promotion.

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.

Screening Applicants

Resumes must be screened against the position description. Where appropriate, particularly in positions of financial responsibility or in dealing with vulnerable clients/children, police checks may be arranged. Previous employers and referees shall be contacted, and transcripts, qualifications and other certification 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. If any member of staff finds that they are assessing any applicant where there is a perceived or actual conflict they shall declare it 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.

New Starter Paperwork

The External Advisor (or 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.

Records and Correspondence

All contact regarding the position is to be directed through reception, with all applications marked "Confidential". Letters/emails of acknowledgement should be posted to all applicants. Short-listed but unsuccessful applicants should be advised that their CV will be retained for future reference unless the applicant advises otherwise.

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 Ashford Education Limited

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 Ashford Education Limited 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 Ashford Education Limited. 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 Ashford Education Limited staff, whether temporary appointees or permanent at any of our operational centres. We expect those organisations whose staff or volunteers attend Ashford Education Limited 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. 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.

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.
  • Ashford Education Limited has clearly worded policies for all staff, representatives and agents with respect to the promotion and marketing of education services overseas.
  • Ashford Education Limited 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; and the cultural relationships.
  • Differences between organisations will be portrayed in a comprehensible and accurate way. No false or misleading comparisons are to be made in relation to other providers.
  • Ashford Education Limited 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.
  • Ashford Education Limited will behave toward other institutions, professional colleagues and other countries in a respectful and courteous manner.

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.
  • Ashford Education Limited 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.

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. The Committee may convene, with appropriate additional expertise if needed, to consider the issue. The Committee's decision will be final.

Communicating the policy

The policy will form part of the Ashford Education Limited 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 Ashford Education Limited. Ashford Education Limited is committed to promoting and celebrating diversity and equality of opportunity; we welcome diversity and differences as a great source of strength.

Ashford Education Limited 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. 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 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, religion or belief, sex (gender) and sexual orientation;
  • oppose and avoid all forms of unlawful discrimination 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; create a working environment free of bullying, harassment, victimisation and unlawful discrimination; promote dignity and respect for all. All staff should understand they, as well as their employer, can be held liable for acts of bullying, harassment, victimisation and unlawful discrimination. Take seriously complaints of bullying, harassment, victimisation and unlawful discrimination.

Statutory Obligations

Ashford Education Limited will meet all statutory obligations under relevant legislation including the Equality Act (2010), Criminal Justice and Immigration Act (2008), The Racial and Religious Hatred Act (2006), The Civil Partnership Act (2004), The Gender Recognition Act (2004), The Human Rights Act (1998), The Protection from Harassment Act (1997), Special Education Needs and Disability Act (2001).

Discrimination within the premises: Ashford Education Limited strongly discourages the practice of discrimination by anyone within its responsibility. Complaints: An individual who feels that they are the victim of discrimination within Ashford Education Limited 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.

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 Ashford Education Limited'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 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 through an audit or risk assessment;
  • Appraisal: that both disabled and other employees will be consulted on the effectiveness of this Company's disability symbol activities;
  • 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.

Procedure

Ashford Education Limited's procedure enables the policy to be implemented, reviewed and revised as appropriate. For wheelchair users an access ramp is sign-posted at the customer street entrance. The portable ramp will be brought to the customer entrance on the site of the building. Where an employee becomes disabled, 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. If, after examining all the options, the company is not able to retain an employee, it will assist them in finding suitable alternative 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.

Statement of commitment and purpose

Ashford Education 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 Ashford Education Limited's value and prospects. The purpose of this document is to describe the methods by which Ashford Education Limited communicates with its shareholders.

Communication with shareholders

The Company Secretary is responsible for communications and compliance with Listing Rules. Methods include: Periodic Reports (annual report, shareholder review, half year report); Announcements of all material information; Annual General Meetings (normally in June); Financial results; Investor and analyst briefings; Shareholder and investor queries. Contact details for the share registry and Investor Relations are provided in the Annual and Half Year reports.

Communication with students

Communications channels used to reach the student population include Ashford Education Limited 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. All Ashford Education Limited communications should be clear, courteous, accurate, appropriate, and timely. Ashford Education Limited 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: Company's management and strategic direction; Day-to-day work related information; Company 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. Formal meetings with students should be recorded on a standard meeting minutes pro forma.

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 should be minuted and filed.

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 Ashford Education Limited is governed. The Board of Directors of Ashford Education Limited is elected by shareholders to supervise the management of Ashford Education Limited's business and affairs with a view to enhancing long-term shareholder value. Ashford Education Limited recognises the need to adhere to best practices in corporate governance.

The Board of Directors

The Board's primary responsibility is to supervise the management of Ashford Education Limited's business and affairs. The Board must provide effective governance over Ashford Education Limited's affairs. 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 Ashford Education Limited.

Board Size

The Board has the authority to fix the number of Directors, which should be in the range of 2 to 10. Candidates for the Board shall be recommended to the Board for approval, taking into consideration the overall composition and diversity of the Board and the areas of expertise that new Board members can offer.

Term Limits

Ashford Education Limited's shareholders elect Directors at the annual meeting each year. The Board believes that its term limits provide an appropriate balance between experience and fresh perspectives.

Board Composition – Qualifications and Considerations

The Board believes that its membership should be composed of highly qualified directors who demonstrate integrity and suitability for overseeing the management of Ashford Education Limited. Factors considered include prominence in business, integrity, demonstrated sound and independent business judgment, knowledge of IT or educational institutions, risk management experience, and the ability to devote sufficient time to Board work. 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 Ashford Education Limited, the regulatory environment, and their duties and responsibilities as Directors. Ashford Education Limited shall assist Directors in their education. New Directors are provided with written information about Ashford Education Limited and their duties.

Other sections

Further sections cover: Other Directorships; Change in Directors' Principal Occupation; Board and Director Effectiveness; Attendance at Meetings; Non-Executive Chairman; Access to Management; Director Compensation; Director Share Ownership; Executive Management; Review Executive Performance; Review Compensation; Oversee Strategic Management; Oversee Risk Management; Disclosure and Communications. Full details are available on request.

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

Ashford Education Limited 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: Consistent (year-to-year format); Straightforward (written for non-specialists); Succinct (concise and to-the-point); Clear (plain English with simple layout).

Annual report contents

The annual report and accounts, taken as a whole, should be fair, balanced and understandable. Key sections include: Highlights; Strategic report (including Chairman's statement, Chief executive's review, CFO review, Directors' report); Report on sustainability, ethics, values, and/or corporate and social responsibility; Board of directors and secretary; Corporate governance report; Independent auditors' report; Financial statements; Shareholder information; Financial calendar; Company information; Registrar and corporate adviser.

The strategic report should include a fair, balanced, comprehensive and understandable review, including an analysis of the development and performance of the company's business, the position of the company at the end of the year, Key Performance Indicators, principal risks and uncertainties, description of the company's principal objectives, strategy and business model, and other matters as required by regulation.

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.

Ashford Education Limited 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

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

Prior to financing the subscription for a new share issue, Ashford Education Limited will conduct a thorough analysis covering: The potential impact of the capital; The likely market response to the issue; The overall sentiment in the stock market; The competence, reliability and reputation of the sponsor(s), lead manager(s), and underwriter(s).

Introduction

The initial public offering (IPO) requires a great deal of effort, cost and management focus. General considerations that an IPO candidate should evaluate 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; Risk factors relevant to the company and industry; The status of the public markets; Investor relations demands. There are a number of other considerations including restrictions on publicity, selection of underwriters, disclosure of related-party transactions, disclosure of executive compensation, structure of the board and board committees, and listing on a stock exchange. Ashford Education Limited believes that they will need a period of 3 to 5 years before seeking public offering. Until that time, Ashford Education Limited 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 on how to recognise and deal with bribery and corruption issues. Bribery and corruption are punishable for individuals by imprisonment. We could face substantial fines, property seizure, exclusion from tendering for public contracts and damage to our reputation. In this policy, the third party means any individual or organisation you come into contact with during the course of your work for us.

Introduction

Ashford Education Limited'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. We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate, including the UK Bribery Act 2010.

Who is covered by the policy?

This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees, consultants, contractors, trainees, volunteers, interns, agents, sponsors, or any other person associated with us.

What is bribery?

A bribe is an inducement or reward offered, promised or provided to gain any commercial, contractual, regulatory or personal advantage. Examples: Offering a bribe (e.g. tickets to secure business); Receiving a bribe; Bribing a foreign official; Gifts and hospitality – this policy does not prohibit normal and appropriate hospitality if it is not made with the intention of influencing a third party, complies with local law, it is given in Ashford Education Limited's name, not in your name, does not include cash, is appropriate in the circumstances, and is given openly. Gifts should not be offered to, or accepted from, government officials or representatives without the prior approval of a member of the Senior Management Team.

Why it is not acceptable

It is not acceptable to give, promise or offer a payment, gift or hospitality with the expectation that a business advantage will be received; to give or offer anything to a government official to "facilitate" or expedite a routine procedure; to accept payment or gifts from a third party that you know or suspect is offered with an expectation of a business advantage; to threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns.

Facilitation payments and kickbacks

We do not make, and will not accept, facilitation payments or "kickbacks" of any kind. If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for. You should always ask for a receipt. If you have any suspicions, raise these with a member of the Senior Management Team.

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. 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.

Record-keeping

We must keep financial records and have appropriate internal controls in place. You must declare and keep a written record of all hospitality or gifts accepted or offered. All accounts, invoices and other documents relating to dealings with third parties should be prepared and maintained with strict accuracy and completeness.

How to raise a concern

You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. Concerns should be reported by following the procedure set out in our Whistleblowing Policy.

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. 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.

Training

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

Who is responsible for the policy?

The CEO has overall responsibility for ensuring this policy complies with our legal and ethical obligations. The CEO has primary responsibility for implementing this policy, and for monitoring its use and effectiveness.

Monitoring and review

The CEO will monitor the effectiveness and review the implementation of this policy regularly. Workers are invited to comment on this policy and suggest ways in which it might be improved. This policy does not form part of any employee's contract of employment and it may be amended at any time.

Schedule – Red flags

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 Whistleblowing Policy: you become aware that a third party engages in improper business practices; a third party has a reputation for paying bribes; a third party insists on receiving a commission or fee payment before signing a contract; a third party requests payment in cash and/or refuses to sign a formal agreement; a third party requests an unexpected additional fee to "facilitate" a service; a third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations; you receive an invoice that appears to be non-standard; you are offered an unusually generous gift or lavish hospitality by a third party; etc.

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.

Ashford Education Limited welcomes feedback from students who are using Ashford Education Limited 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 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 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 is, in essence, informal but with an emphasis upon prompt resolution. 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 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 have been taken to resolve it informally, and explaining why the outcome is not considered appropriate or satisfactory. 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, contact the complainant and indicate what action they plan to take, and the date by which they expect any investigation to be complete.
  • 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, 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 Ashford Education Limited can avail themselves of the intellectual property rights conferred upon them to operate the system.

Intellectual Property Rights

  • Ashford Education Limited agrees not to use any Courses or other IPR other than as expressly permitted by the relevant Agreements.
  • Ashford Education 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 updates and adaptations to Course(s) materials) belongs to any other party, unless the Parties agree otherwise in writing.
  • Ashford Education 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.
  • Ashford Education 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 must do all such things as may be reasonably required to assist in taking or resisting any proceedings in relation to any such infringement or claim.
  • Ashford Education 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 or consultant etc acts in breach of it. This includes explaining the policy to all relevant staff, carrying out any necessary training and including appropriate clauses in contracts of employment or engagement.
  • Any other party agrees that Ashford Education Limited has developed the product over a long period and as such all IP rights will remain the property and copyright of Ashford Education 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 Ashford Education Limited 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 required in other jobs in the Academy, so that flexibility may be achieved at all levels; 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. Senior management will identify opportunities for staff development. Each year staff should spend at least two full days on personal development, or more if there is sufficient justification. As awarding body policies and procedures are updated, relevant staff will be invited to attend update or refresher sessions. Staff are to be supported in maintaining their continuous professional development (CPD) portfolio. Staff are encouraged to join and upon request will be supported in becoming members of the Institute for Learning.

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.

Staff Grievance Procedure

  • Dealing with grievances informally: If you have a grievance or complaint to do with your work, 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. 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. 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). 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. This absence policy explains what we expect from managers and employees when handling absence, and how we will work to reduce levels of absence to no more than five days per employee per year.

Key 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 will support employees who have genuine grounds for absence, including 'special leave' for necessary absences not caused by sickness, a flexible approach to annual leave, access to counsellors where necessary, and 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.
  • We will use an occupational health adviser, where appropriate. We respect the confidentiality of all information relating to an employee's sickness. 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, give a clear indication of the nature of the illness and a likely return date. 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.

Return to work discussions

Managers will discuss absences with employees when they return to work to establish the reason for absence, anything the manager or the Academy can do to help, and that the employee is fit to return to work. A more formal review will be triggered by frequent short-term absences or long-term absence. Absences relating to the disability of an employee or to pregnancy will be kept separate from sickness absence records. 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.

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. 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 will be conducted by, or arranged by, the Academy Director.

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. Persons identifying irregularities will not be adversely affected as a result of 'whistle blowing'. 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 will be viewed as a potential instance of irregularity and will invoke an investigation. 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. Where the first offence is sufficiently serious, 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 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.