Lifting the coronavirus lockdown: Incorporatewear Ltd Policy on safe working during the COVID-19 pandemic…..
As the coronavirus (COVID-19) lockdown is eased, we recognise that our organisation needs to return to normal operations where possible and adapt to new ways of working when and where required. This policy explains the changes to our working environment and new ways of working.
These adaptations have been informed by our COVID-19 risk assessment, results of which can be found below. We have consulted members of the Senior Team and those colleagues currently engaged at both sites.
We have identified the minimum number of workers needed to operate safely and effectively, while maintaining social distancing, in our work locations.
We are asking workers to attend work only where their role requires their physical presence. Workers who can work from home, such as support/administrative staff, continue to do so.
Workers with serious underlying health conditions who have been advised to shield against coronavirus should continue to do so for the duration of their shielding period. Workers who are sole carers for those identified as vulnerable groups will be consulted individually about potential adaptations and those that are pregnant workers and those aged 70 or over will also be consulted individually about potential adaptations to their role.
If you or someone you live with has coronavirus symptoms
It is absolutely essential that if you or anyone you live with develops:
- a fever, particularly a high temperature (i.e. a temperature of 37.8 degrees or over); and/or
- a continuous cough,
- Loss of smell or taste,
You do not attend ICW site’s and self-isolate in accordance with the Government’s guidance at
These are the primary symptoms and others do exist.
Incorporatewear is now registered with HM Government as an ‘Essential Business’; please notify the business if you believe you or those you live with are showing symptomatic signs of the COVID 19 Virus?
Travel to and from work
We encourage workers to minimise their use of public transport, including by walking or cycling where possible. If travelling by car, you must not car-share with anyone outside your household.
Where you need to use public transport, please think about social distancing, where possible staying two metres away from others and avoiding touching surfaces. If you can, wear a face covering on public transport. Face Masks will be supplied to all ICW colleagues who attend site.
Workers using public transport may find it helpful to refer to the Government’s guidance at:
Hand sanitising stations will be available upon your arrival at work, you must apply before any further progress onto site is made. You should also wash your hands thoroughly as soon as you get home from work.
To reduce the risk of infection spread, we have introduced the following measures for the warehouse colleagues:
- No more than 7 colleagues will be allowed on a set shift; these will be fixed against staggered start and break times. So as an example, we may have 7 colleagues start at 8am and another 7 start at 8:30am; subsequent breaks taken in line with our general breaks every 2 hours.
- The breaks will also be staggered against each team so as to avoid backing up e.g. making a cup of tea.
- Where possible, colleagues will be placed in the same working environment on the same task on a daily basis to limit the number or spread of different individuals covering various tasks.
Office Based personnel:
- If you are able to work from home then this advice remains.
- If you have to attend work then look to avoid the high traffic times of entry to site; it is recommended to attend site Post 8:30 am so as to avoid mingling with the warehouse staff on entry.
- Avoid canteen at break times for warehouse colleagues where possible
- Hot Desking will not be permitted for the foreseeable future.
- Avoid steering from desk to desk, keep to your personal working environment.
Hygiene, cleanliness and New Procedures.
To reduce the risk of infection spread, we have introduced the following measures:
- Entry to site will now be through a single entry point (New Side Door Entry at HH).
- All staff will sanitise their hands before progressing, this will be inclusive of all visitors or contractors.
- An ‘Infra-red’ thermometer (non-intrusive) temperature reading will be taken of every individual attending site. Face masks to be worn by the person taking the reading and those to receive the reading; further shielding will be in place.
- A reading greater than 100.040 F (37.80 C) can give a very strong indication of fever; if such a reading was taken. The individuals involved will be asked to wait 10 minutes, ensuring segregation from all staff. A second reading will be taken, if temp is confirmed for a second time, you will be asked to return home and details taken to register symptoms with the NHS testing programme.
- Face masks will be issued to all staff and it is expected that any situation that cannot be avoided in terms of being in close proximity to other staff, then you will wear your facemask. It is currently recommended to wear facemasks on public transport if you have no alternative.
- Contract cleaning hours have been extended to focus on regular touch points.
- Each individual will nominate a canteen table to themselves at arrival to work; this table will effectively be your table every time you spend time in the canteen for the day, week etc. however long it takes for distancing measures to be relaxed. Wipes will be allocated to every table; at the end of every rest period including arrival at work, you are required to wipe down your table to ensure a clean table for the next shift/person.
- Each table will be numbered indicated by the wipes, this will also indicate the sequence in turn of taking your break.
- More than 1 person in the toilet is to be avoided.
- VACANT/OCCUPIED signage will be applied to all toilets.
- All Doors that do not provide security to site will be kept open however, please note that in the event of an emergency exit, you must close doors as you leave the building. (In the event of a site evacuation, social distancing remains in force at assembly area)
- Hand sanitiser is available throughout the site and use is to be encouraged especially at break times.
- Fogging agents will be used on a weekly basis to sanitise heavy traffic areas such as the canteens. These are designed to sanitise the whole area and spots that are difficult to reach with normal cleaning routines.
- Sanitising ‘Quick Dry’ sprays will also be available to support frequent sanitising of equipment which may require more than 1 person to handle at different times e.g. Fork Lift Truck. These sprays once applied remain effective for a good number of days.
- Issued facemasks are washable & re-usable, it is expected for you to take care of these items and wash frequently.
- Staggered break times introduced to ensure personnel have space to use wash facilities and to make themselves some refreshments however, if you do find that you are close behind your colleague please keep to the 2m distancing and allow space for the individuals to complete whatever they are doing (Please note that staggered breaks will be subject to on-going review)
- Signage throughout the site to remind you of the distancing rules.
- Use of ‘Lift’ is limited to one person at a time but please avoid any use if possible.
- Rules applied to social distancing within the canteen area are equally applicable to the galley kitchens. Please respect social distancing if someone is already utilising these kitchens
- If you do use the kitchen, Galley Kitchens, please wipe down the surfaces after every use e.g. fridge handles, microwaves, preparation surface etc.
- Try to utilise the same equipment on a daily basis e.g. take ownership of a picking gun and continue to use and own this gun, picking trollies etc. These items will be sanitised on a weekly basis which will remain effective for the week.
- Use of smoking area is also inclusive of abiding by the 2m distancing rules.
- Disposable gloves to be provided and worn when processing returns.
Playing your part
While we are taking these stringent additional measures, we would like to remind colleagues, visitors and contractors to play your part by:
- Washing your hands often and thoroughly; scientific evidence suggests washing hands at least 6 times a day can greatly reduce your chances of infection.
- avoiding touching your face, particularly your eyes, nose and mouth; and
- Coughing or sneezing into a tissue, and binning it safely, or into your arm if a tissue is not available.
- Observing Social Distancing rules outside of work.
We cannot control what you do outside of work but please bear in mind the responsibility you have to yourselves, your family, your colleagues & your colleague’s families.
We as a business are doing all we can to ensure that you are working in a safe environment but the very nature of our work against the processes that we use may cause conflict to the social distancing measures?
We ask you to apply common sense, we can control certain activities but we will at times have to cross paths.
Social distancing measures
While at work, you must maintain social distancing of two metres wherever possible. Please apply the following measures if you have to negotiate a conflict with this instruction:
- If it is a case of having to pass another colleague, then pass with your back to that person.
- If you are at a location required to complete a task and a colleague is in the same area completing their own task, look to delay, find another task, leave until an appropriate time.
- If you have to be in the general proximity of another colleague for an extended amount of time then please use your facemask but this does not mean it’s OK to stand side by side, shoulder to shoulder.
- If you have to communicate, then at a distance.
- Avoid group conversations, these tend to draw people closer and others in.
- Actively remind each other of social distancing and respect individuals that highlight.
As part of our social-distancing measures, workers should conduct meetings remotely where possible. When physical meetings are necessary:
- only essential participants should attend the meeting;
- meetings should be kept as short as possible;
- social distancing of two metres should be maintained throughout;
- objects such as stationary should not be shared; and
- Meetings should be held [outdoors/in a well-ventilated room] whenever possible.
- All visitors will have to access site through the designated entrance and undergo a thermal scan.
Hand sanitisers are provided in meeting rooms and areas where meetings frequently take place.
Customers and visitors
To reduce the risk of infection spread, we have introduced the following measures:
- restricting the number of customers allowed in at any one time, bearing in mind the space available and the need to maintain social distancing;
- suspending or reducing customer services that cannot be undertaken without contravening social-distancing guidelines;
- providing clear guidance to visitors, such as delivery workers;
- allowing for non-contact deliveries,
- Visitors to site will need to follow the rules indicated above for site entry (This excludes delivery drivers)
The use of a face covering is not a replacement for observing our social distancing guidelines.
Law relating to this document
Leading statutory authority
Health and Safety at Work etc. Act 1974
Management of Health and Safety at Work Regulations 1999 (SI 1999/3242)
Equality Act 2010
Our plan to rebuild: The UK Government’s COVID-19 recovery strategy
working safely during coronavirus (COVID-19)
Duty of care
Employers have a common law and implied contractual duty to take reasonable care for the health and safety of every worker. Additionally, the Health and Safety at Work etc. Act 1974 requires employers to take all reasonably practicable steps to ensure the health, safety and welfare at work of all their workers. This means that return-to-work plans need to take account of the health and safety of returning workers.
- Carried out a COVID-19 risk assessment and shared the results with staff.
- Put in place cleaning, handwashing and hygiene procedures in line with government guidance.
- Taken all reasonable steps to help staff to work from home.
- Taken all reasonable steps to maintain two-metre social distancing in the workplace.
- Where people cannot be two metres apart, done everything practical to manage transmission risk.
28th May 2020
Corporate Social Responsibilty
Committed to Making Positive Economic, Social and Environmental Contributions to Society
It is the responsibility of every business to take account for its impact on people, society and the environment. As members of SEDEX we take the CSR of our entire supply chain very seriously and our membership allows us to store, share and report on all of our suppliers. We only work with suppliers that meet the very stringent checks required to conform to the SMETA Audit process.
Incorporatewear, along with our parent company, Wesfarmers, are committed to making positive economic, social and environmental contributions to society, consistent with the principles of honesty, integrity, fairness and respect. We prohibit discrimination, forced, trafficked and child labour and are committed to safe and healthy working conditions, including the right to freedom of association and collective bargaining. We will only work with suppliers who operate in line with our Code of Conduct and Ethical Sourcing Policy.
Addressing Human Rights Impacts
We recognise that we must take steps to identify and address any actual or potential adverse impacts with which we may be involved whether directly or indirectly through our own activities or our business relationships. We manage these risks by integrating the responses to our due diligence into our internal systems, acting on the findings, tracking our actions and communicating with our stakeholders about how we address impacts.
Anti Slavery Policy
Incorporatewear opposes slavery in all its forms. This statement is made pursuant to Section 54, Part 6 of the United Kingdom’s Modern Slavery Act 2015 and sets out the steps Incorporatewear has taken to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business.
1. Ethical sourcing audit programs
To mitigate the risk of unethical practices occurring in our supply chains, we apply an ethical sourcing audit program to higher risk suppliers. Suppliers are considered lower risk if they operate in more regulated countries or if they are supplying proprietary brands.
Factories in the audit program are required to have a current audit certificate, which means they have been audited by us or another party whose audits we accept. Those audits identify a range of non-compliances, from minor non-compliances such as minor gaps in record keeping to critical breaches, such as incidents of bribery or forced labour.
Forced labour indicators, such as restriction of movement, intimidation and threats, retention of identity documents, withholding of wages, debt bondage, abusive working and living conditions and excessive overtime are explored as part of the ethical audit formats approved under our audit program.
Where a non-compliance is identified, the supplier site is required to fix the issue, within an appropriate period of time, depending on the nature of the non-compliance. Supplier sites are ‘conditionally approved’ if non-critical non-compliances have been identified and notice has been given that they must be fixed. If a supplier site then addresses a non-compliance, it can move to becoming an ‘approved’ supplier site.
If critical breaches are identified, they must be addressed immediately. If they are addressed satisfactorily, a supplier site can then become approved. In this way, our audit process is contributing to improving conditions for workers by working with supplier site owners to address any issues. If a supplier site is not willing or able to address a critical breach, our business will not continue to buy from that supplier site.
3. Ethical sourcing training
We keep our buying and sourcing teams up-to-date on our ethical sourcing commitments and how their actions may impact worker rights. We regularly deliver ethical sourcing training to our team members in our retail businesses and supply chains to refresh their knowledge on this subject.
We continue to build the awareness and knowledge of our employees and workers on human rights, including labour rights, encouraging them to speak up, without retribution, about any concerns they may have, including through our grievance channels. We also promote the provision of effective grievance mechanisms by our suppliers.
Supplier Sustainability Code
Incorporatewear also abide by a Supplier Sustainability Code. The purpose of this policy is to provide a purchasing framework that will advance the sustainable use of resources. ICW intend to demonstrate to the community that the purchasing decisions of its employees can improve markets for recycled products, enhance environmental quality and be responsible.
Incorporatewear Limited UK Tax Strategy
The publication of this tax strategy is regarded as satisfying the statutory obligation, under Part 2 of Schedule 19 of the Finance Act 2016, for Incorporatewear Limited Incorporatewear for the period ended 30 June 2018. The ultimate parent company of Incorporatewear is Wesfarmers Limited Wesfarmers, an Australian public company listed on the Australian Securities Exchange.
Incorporatewear provides bespoke corporate clothing solutions to large blue chip clients worldwide. Incorporatewear has been supplying inspirational corporate wear for more than 20 years and has a wearer base in excess of 350,000.
Commitment to compliance
Incorporatewear is committed to full compliance with its statutory obligations and takes a conservative approach to tax risk. Incorporatewear aims for certainty on all tax positions it adopts. Where the tax law is unclear or subject to interpretation, professional advice is obtained, and when necessary the UK tax authorities (or other relevant tax authority) are consulted for clarity.
The Incorporatewear tax policy is aligned to the Wesfarmers Group tax policy. Key aspects of the Wesfarmers Group tax policy are outlined within the Wesfarmers 2017 Tax Contribution Report and include an internal escalation process for referring tax matters from the Incorporatewear’s Head of Finance to the Wesfarmers Group Tax Function. The Executive General Manager of Wesfarmers Group Finance is required to report any material tax issues to the Wesfarmers Board.
Attitude of the group towards tax planning
Incorporatewear’s approach to tax planning is aligned with Wesfarmers’ approach to operate and pay tax in accordance with the tax law in each relevant jurisdiction. Incorporatewear will not engage in artificial transactions, the sole purpose of which is to reduce UK tax.
Approach to tax risk management
The Head of Finance of an Australian parent entity, as Senior Accounting Officer, is responsible for ensuring that appropriate policies, processes and systems are in place and that these are reviewed for operational effectiveness.
Incorporatewear’ manages its tax affairs in consultation with PwC. Incorporatewear will always seek external advice on tax consequences where the transaction is material or complex.
Relationship with HMRC
Incorporatewear seeks to adopt a transparent and collaborative relationship with the UK tax authorities (HM Revenue and Customs). In particular, Incorporatewear seeks to:
- engage in full, open and early dialogue with the UK tax authorities to discuss tax planning, strategy, risks and significant transactions;
- make fair, accurate and timely disclosure in correspondence and returns, and respond to queries and information requests in a timely fashion;
- resolve issues with the UK tax authorities in real time and before returns are filed if possible, and where disagreements arise, work with the UK tax authorities to resolve issues by agreement (where possible);
- be open and transparent about decision making and governance;
- have reasonable grounds to believe that transactions are structured to give a tax result which is not inconsistent with their economic consequences (unless specific legislation anticipates that result), nor contrary to the intentions of Parliament; and
- interpret the relevant laws in a reasonable way.
30th June 2018
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