Shepley Group Company Manual 2014 Contents RENEW Engineering Services ...................................................................................................... 3 Organisation ....................................................................................................................................... 4 Shepley Engineers Ltd (SEL) ....................................................................................................... 5 PPS Electrical Ltd (PPS) ................................................................................................................. 5 West Cumberland Engineering Ltd (WCEL)............................................................................ 5 Mothersill Engineering Ltd (MEL) ............................................................................................... 5 Organisational Commitment ........................................................................................................ 6 Employee Commitment.................................................................................................................. 6 General Health & Safety Guidance ............................................................................................ 6 Environmental Management Approach .................................................................................... 7 Quality Management Approach ................................................................................................... 8 Equal Opportunities ......................................................................................................................... 9 Code of Ethics .................................................................................................................................. 10 Principles............................................................................................................................................ 10 Bribery & Corruption ..................................................................................................................... 10 Personal Conflict of Interest....................................................................................................... 10 Equity & Fairness in Conduct of Competition ...................................................................... 11 Confidentiality and Protection of Intellectual Property .................................................... 11 Hospitality & Gratuities ................................................................................................................ 12 Facilitation Payments ................................................................................................................ 12 Government Employees........................................................................................................... 12 Sub-Contractors, Consultants & Agents ............................................................................ 12 Security .............................................................................................................................................. 12 Alcohol, Drug & Substance Abuse ........................................................................................... 13 RENEW Engineering Services Our Businesses and Capabilities The Shepley Group of companies are a wholly owned subsidiary of Renew Holdings plc. Renew provides multidisciplinary engineering services to maintain and develop UK Infrastructure in the Energy, Environmental and Infrastructure markets. Organisation Shepley Engineers Ltd Robinson House Crow Park Way Westlakes Science Park Moor Row Cumbria CA24 3HY Tel: 01946 599022 Construction Site 3 Sellafield Seascale Cumbria CA20 1PG Tel: 019467 28962 Construction Site 5 Sellafield Seascale Cumbria CA20 1PG Tel: 019467 21563 Springfields Salwick Preston Lancashire PR4 0XY Tel: 0177 2732 184 Shafton Works Engine Lane Barnsley South Yorkshire CA20 1PG Tel: 01226 780 200 Palace of Westminster Parliament Square London SW1A 2PW PPS Electrical Ltd 187 Duke Street Barrow-in-Furness, Cumbria, LA14 1XU Tel: 01229 433 838 Site 1, Sellafield, Seascale, Cumbria, CA20 1PG Tel: 019467 78900 West Cumberland Eng Joseph Noble Road Lillyhall Workington Cumbria CA14 4JX Tel: 01900 872 787 Mothersill Engineering Ltd Joseph Noble Rd Lillyhall, Workington, Cumbria, CA14 4JX Tel: 01900 872 918 Shepley Engineers Ltd (SEL) Shepley Engineers Limited is a wholly owned subsidiary of Renew Holdings plc. Based in Cumbria we are a major contractor and project manager specialising in term contract works predominantly within the nuclear and chemical process plant environments. Our work involves high integrity site and workshop activity within these particularly challenging sectors. Shepley have also developed a highly specialised capability associated with the sympathetic restoration and conservation of historically significant iron structures. Through both organic growth and a number of complementary acquisitions, the Shepley Group is now established to provide a very integrated and multi-disciplined service offering. PPS Electrical Ltd (PPS) PPS Electrical are a well-established specialist electrical and instrumentation contractor who have developed an excellent reputation within the nuclear and chemical process plant environments. Our work involves a comprehensive range of electrical and instrumentation support within these particularly challenging sectors. We have a head office including a large workshop and panel manufacturing facility in Barrow in Furness as well as a number of site specific establishments. At Sellafield, where we have been engaged for over twenty years, we have an office complex and a site compound including stores and a large workshop. PPS Electrical are a JIB registered organisation and members of the Electrical Contractors Association as well as the ECIA. We have a very healthy training and development agenda with a large domestic apprenticeship scheme to deal with the anticipated future demands within our sector. West Cumberland Engineering Ltd (WCEL) WCEL are a well-established and experienced fabrication company focusing on the manufacture and installation of high quality welded fabrications such as process pipework, tanks, vessels, modules, waste containers and high integrity ductwork mainly for the nuclear and petrochemical industries. The management team and workforce have considerable experience in servicing the high quality demands within these important and challenging sectors. The extensive facilities at our Lillyhall works are also widely utilised for final assembly, mock-ups, testing & familiarisation training prior to the installation of equipment within the live plant environment. WCEL have developed a very flexible and responsive fabrication service which can be applied across a wide range of task size. Mothersill Engineering Ltd (MEL) Mothersill was established in 1983, primarily to provide machining services for the Sellafield nuclear site. For over thirty years focus remains within the nuclear and chemical process plant environments, which demand extremely high levels of service and conformance. Procedures have been developed to comply with the rigorous standards demanded in these sectors and our experience now include the delivery of over forty thousand successfully completed orders. MEL have a dedicated facility comprehensively equipped with a wide range of conventional and CNC machining resources. Organisational Commitment It shall be the duty of every group organisation to ensure, as far as reasonably practicable, the health, safety and welfare of all their employee’s. Dispute avoidance is an overriding commitment. Excellent relationships with clients, colleagues and suppliers must be maintained at all times. Continuous improvement of behaviour, skill and competence. Employee Commitment “Employees must take reasonable care for their own and other’s health and safety at work, and to co-operate with their employer to enable them to meet and comply with all relevant statutory provisions.” “It is an offence for anyone to intentionally or recklessly interfere with, or misuse anything provided in the interests of the pursuance of these statutory health and safety provisions.” General Health & Safety Guidance You are not to undertake any tasks that you are not trained or have had adequate instruction for. Always adopt a questioning attitude, think ‘What is the worst thing that could happen?’ If you witness anything that you feel is unsafe, you are actively encouraged to challenge the individual or situation and explain what your concerns are. If in doubt – ASK, DON’T WALK BY. If you yourself are challenged by anybody, please ensure you are courteous and if able to, answer any questions put to you. PPE is issued to you free of charge by your employer, for your protection. PPE MUST be worn when instructed to do so. You are to take notice of, and obey safety signs and signals. Be familiar with the safety hazards of your job and ensure that your tools are in good condition and fit for purpose. If you have an accident or receive an injury at work then you must follow the local guidance and report to the first aid post for treatment and formally record the accident in the company accident book. If you have sustained any wounds, cuts etc then report to the first aid team to have the wound assessed prior to accessing your work area. Implement and maintain effective health and safety systems by recognising hazards and adopting appropriate controls to mitigate known risks. Comply with legal and moral obligations and where applicable client requirements. Investigate all accidents in order to learn from experience and implement counter measures to prevent re-occurrence. Encourage the participation and reporting of health and safety issues in order to continuously improve the Health and Safety management systems. Work closely with clients in order to understand and empathise with their safety concerns and drivers in order to remain compliant with their requirements by flowing down their Health and Safety requirements. PLEASE CONTACT YOUR LOCAL SAFETY ADVISOR FOR FURTHER INFORMATION Environmental Management Approach Both Shepley Engineers Ltd and PPS Electrical Ltd are EN ISO 14001:2004 certified by the BSI, an accredited certification organisation overseen by the United Kingdom Accreditation Service (UKAS). West Cumberland Engineering and Mothersill Engineering adopt the processes and procedures defined by both Shepley Engineers and PPS allowing best practise to be fostered across the group. Determine our environmental aspects and their resulting impacts. Set objectives and targets to minimise the environmental effects of our impacts. Record and monitor our environmental impacts. Be aware and cautious about introducing polluting materials. Train staff in environmental awareness, emergency plans, pollution avoidance, spill control and waste disposal. Comply with all regulatory and client requirements as applicable. Ensure that the supply chain is fully aware and work within the law and the terms of our policy statement. Report all breaches of environmental legislation. Ensure the lawful disposal of all waste. Minimise noise and visual impact of equipment and work practices. Remove all materials, equipment and waste from site at the end of a contract. Work closely with clients in order to understand and empathise with their environmental concerns and drivers in order to remain compliant with their requirements by flowing down their environmental requirements. Quality Management Approach All companies are EN ISO 9001:2008 certified by establishments accredited by the United Kingdom Accreditation Service (UKAS). Achieve customer satisfaction by implementing a quality management system which demonstrates full traceability and control of customer deliverables throughout the project lifecycle. Undertake periodic reviews of the quality management system in order to demonstrate procedural effectiveness at all levels. Implement a schedule of internal audits in order to demonstrate compliance and effectiveness of the quality management system. The Shepley Group board will periodically review the output and effectiveness of the quality management system. Define, delegate and deploy effective resources, plant and equipment in order to realise customer expectation of the desired product. Continuously monitor, verify and validate the customer deliverables in order to demonstrate full realisation of the customer requirements and monitor change and deviation from the original design definition. Monitor the effectiveness of the supply chain. Work closely with clients in order to understand and empathise with their quality concerns and drivers in order to remain compliant with their requirements by flowing down their quality requirements throughout the supply chain. All employees will be suitably trained and competent to perform their tasks in order to achieve the desired results. Quality objectives are defined and measured in order to continuously monitor and improve our systems and approach. On certain projects specific client requirements are adopted and flowed down throughout the supply chain as required. Equal Opportunities The Shepley Group is committed to the successful management of Equal Opportunities in respect of all past and present employees and job applicants. Our objective is to ensure that no employee or job applicant is either directly or indirectly discriminated against on the grounds of gender, marital status, colour, race, nationality, ethnic or national origin, disability, sexual orientation, religious belief, age, membership or non-membership of a trade union. The group recognises its obligations under current legislation and any associated codes of practice. As such we regularly monitor for change to ensure that any new requirements, commensurate with being a responsible and caring employer, are incorporated, as appropriate, into our activities. Appropriate processes and procedures are implemented and continuously reviewed to ensure that individuals are treated equally, fairly and with dignity and that decisions relating to recruitment, selection, training, promotion, dismissal, redundancy and career development are based solely on objective criteria. The success of this policy is dependent upon the cooperation of all employees within the organisation and appropriate training will be provided to ensure that all are fully aware of their rights and responsibilities in relation to Equal Opportunities. Any breach of this policy by an employee including victimisation, discrimination, bullying and harassment of another individual will not be tolerated, nor will it be acceptable to help others do so. Any such occurrence will be fully investigated and may lead to disciplinary action, up to and including dismissal, being taken against those responsible. It should also be noted that employees who carry out such unlawful acts against another individual may have committed a criminal offence and be liable to prosecution. The requirements of this policy will be fully incorporated into the relevant operating procedures within the group’s management system and will be subject to regular review to ensure their continued applicability and suitability. Code of Ethics Integrity, professionalism, honesty and respect whether personal or organisational are indispensable in the commercial environment & are essential requirements for any organisation in order to grow and ensure profitability and continuing business success. Accordingly, commercial and contract management requires a clear policy statement and a specific set of values relative to professional ethics in order to earn and maintain the confidence of both customers and the supply chain. This code of ethics is promulgated as such guidance for all personnel involved directly or indirectly in organisational activities. Principles No one with a personal or organisational conflict of interest may participate in any way in the formation or administration of a contract. All companies seeking procurement work from the organisation shall be treated fairly and equitably and their intellectual property shall be protected and used only for the purposes intended by its owner. All personnel involved in any way in the contracting process shall comply with all amicable laws, regulations and directives as well as their specific contractual obligations. The integrity of the commercial processes shall never be tainted by any real or perceived improper activities. Bribery & Corruption In accordance with the legislation terms of the UK Bribery Act no individual(s) will offer, promise or give a financial or other advantage to another person(s) with a view to inducing a person(s) to perform improperly a relevant function or activity or reward a person(s) for the improper performance of their activity. Personal Conflict of Interest All personnel involved in a procurement transaction must disclose any actual or potential conflict of interest which could exist or perceive to exist to their relevant management. If a conflict of interest is determined, the disclosing person will be directed to remove themselves from any further involvement in the specific process. All commercial and contract management personnel with the potential for influencing a procurement transaction in any way shall inform their relevant management. A view will be determined as to whether the activities should be re-directed. Disclosure of potential personnel conflict of interest shall not result in any adverse action against the individual(s). Equity & Fairness in Conduct of Competition No preference or advantage shall be afforded to any contractor or potential contractor. Similarly no prejudice against any contractor or potential contractor shall be tolerated. Examination of documented contractor performance information is considered without preference or prejudice. Specifications or requirements must not be biased in favour of any particular contractor or potential contractor. Implying large quantities to influence price, when knowing that the actual order will be smaller is not permitted. Wording of invitations for tenders, other solicitations or specifications or statements of work in a vague way to intentionally induce misinterpretation or errors in proposals are unethical and prohibited. Solicitation of proposals from suppliers known to be unqualified for the award with intent to create the illusion of competition is dishonest and is not permitted. Solicitation of other proposals to create competitive pressure on a certain sole source supplier is prohibited. Bid or proposal information from one proposal may never be shared with another contractor or potential contractor even if either of the competitors has been eliminated from the competition. No criticism of one potential source should be communicated to another contractor or potential contractor nor should the strengths or weaknesses of a contractor or potential contractor to be disclosed to any organisation whether competing or not. Confidentiality and Protection of Intellectual Property Information submitted by competitors or proposers is the property of the entity that submits the information and must be protected from disclosure to personnel or firms not authorised to be involved in the evaluation of proposals. All such property submitted shall be controlled as dictated within the contractual obligations. Copyrighted or patented information shall never be reproduced without the express written authorisation of the owner. Hospitality & Gratuities In order to avoid being misconstrued as consideration for special treatments or as an attempt to positively influence their attitudes or decision making personnel should not give or accept hospitality which contravenes the UK Bribery Act. It is recognised that the giving and receiving of tokens of appreciation is a fundamental part of building good business relationships and maintaining understanding and goodwill. No individual(s) shall request, agree to receive, anticipate or accept a financial or other advantage with the specific intention of performing a function or business activity improperly either directly or via a 3rd party. No individual(s) will offer, promise or give financial or other advantage to another person(s) where that individual(s) believes that the acceptance of the advantage would itself result in an improper performance of a relevant function or activity. Facilitation Payments A facilitating payment is a certain type of payment to foreign officials which is not considered to be bribery according to legislations of some states but may be construed as bribery within the UK and as such is in opposition to the UK Bribery Act. It is therefore against company policy to authorise such payments without the consultation of the legal department. Government Employees No gift or hospitality whatsoever is to be offered to any government or local government official without the express approval of the Managing Director who will take steps to ensure that no governmental or statutory practise is being breached. Sub-Contractors, Consultants & Agents Any sub-contractor, consultant or agent operating on behalf of the company will be expected to fully comply with this guidance. Security Information will be protected against unauthorised access. Protected sensitive information will be physically stored in lockable storage accessed only by authorised key holders. Key control will be enforced. Access to the premises is controlled at all times. Statutory employment checks will be carried out including nationality and identification verification. This will include agency supplied workers. Confidentiality of information will be assured by operating a “need to know” approach. All breaches of security, actual or suspected, will be reported and investigated. It is the responsibility of each employee to maintain organisational security. A risk based approach is adopted in order to maintain an appropriate level of confidentiality, integrity and availability of the company’s assets. Respect client security requirements. Many documents will be marked RESTRICTED or to a lesser extent PROTECT. In all cases a disclosure of such information constitutes a breach of client confidence. In the case of RESTRICTED, disclosure relates to a statutory breach of legislation. Specific to Nuclear Licensed Sites Clause 79 of the Anti-Terrorism, Crime & Security Act 2001 - Prohibition of disclosure relating to nuclear security is applicable. “A person is guilty of an offence if they disclose any information or similar the disclosure of which might prejudice the security of any nuclear site or of any nuclear material with the intention of prejudicing that security; or being reckless as to whether the disclosure might prejudice that security.” A person guilty of an offence under subsection is liable on conviction on indictment, to imprisonment for a term not exceeding seven years or a fine (or both); and on summary conviction, to imprisonment for a term not exceeding six months or a fine not exceeding the statutory maximum (or both). Only store RESTRICTED information at locations which have been approved for use by the UK civil nuclear industry, via the contracting authority. Alcohol, Drug & Substance Abuse The Policy on Alcohol and Drugs is a fundamental part of the company’s strategy to safeguard the health, safety and welfare of all its employees. The limit for alcohol set by this policy is in line with the Government’s legal drink/drive limit. In the case of drugs the threshold levels are determined in accordance with established legal and medical practice. Consumption, possession or sale of illegal drugs is prohibited. The Company has a zero tolerance approach to this. Possession and sale are criminal offences under the Misuse of Drugs Act 1971 and will constitute gross misconduct. Employees must not present themselves for work under the influence of alcohol or drugs so that their performance or ability to carry out their activities at work safely and competently is impaired in any way. The company reserves the right to test any employees who exhibit these symptoms or behaviours. Consumption of alcohol or drugs during normal working hours or at any time on Company premises is prohibited. When representing the company outside normal working hours, employees are expected to take a responsible attitude to alcohol. Employees must bear in mind that they are representing the Company and must not do anything to jeopardise its reputation. This Policy covers those driving any vehicle on behalf of the company in any capacity or at any location. This Policy covers travel to and from work if it could reasonably be implied that alcohol or drugs were present outside the prescribed limits during normal working hours. Prescribed and over the counter medications are also covered by this Policy as they may cause side effects that have potential safety implications. Employees therefore have a duty to advise their pharmacist/general practitioner/medical practitioner of this Policy when being prescribed medication. On the advice of the medical practitioner, the employee must notify his or her manager about any possible impact on his/her health and safety relating to his/her duties at work, so that current or alternative employment can be considered whilst he/she is being prescribed medication. The manager may in turn seek advice from the company doctor. Any employee engaged on safety critical tasks might require to be provided with alternative work during the period of medical treatment. Employees or other persons obtaining treatment or medicines for themselves should be aware of the conditions and side effects notified and seek out alternatives that do not impair performance through drowsiness or other symptoms. If in doubt an employee should self-refer, or be referred, to the company doctor. Any visitor who is attending the Company’s premises or site for business reasons shall be required to comply with this Policy and should be asked to leave the premises or site if they are acting in a manner likely to cause a breach of this Policy. Other members of the general public, for example, in their capacity as customers or clients, should be asked to leave if their behaviour indicates that they may be under the influence of alcohol and/or drugs. Registered Office Renew Holdings plc Yew Trees Main Street North Aberford West Yorkshire LS25 3AA Company Registration Number 2926871
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