POLICIES

Anti-Bribery Policy

The Company is committed to acting professionally, fairly and with integrity in all its business dealings and relationships and implementing and enforcing effective systems to counter bribery. As such no employee should accept (unless prior consent has been obtained from a Director) any gift, payment and/or favour of whatever kind from any customer, client or supplier; or any prospective customer, client or supplier of the Company save for gifts of little value such as diaries. In addition, no employee should offer inducements to any customer, client or supplier whether current or perspective in order to gain a commercial, contractual, regulatory or personal advantage. (This does not include the Company’s general customer/supplier entertainment schedule as this has been deemed to be acceptable under current applicable legislation)

The Company does not make contributions/donations, whether in cash or kind, in support of any political parties or candidates, as this can be perceived as an attempt to gain an improper business advantage.

Charitable support and donations are acceptable (and indeed are encouraged) whether in kind services, knowledge, time or direct financial contributions. However, consent should be obtained from management before agreeing to any support or donation and consideration should be given as to whether it could be considered as some form of bribery.

All employees are encouraged to be vigilant, and report to a Director as soon as possible if they have any concerns, regarding potential breaches to this policy. All reports made under this policy will be investigated thoroughly and in confidence. The Company will support anyone who raises genuine concerns and no employee making a report in good faith (even if they turn out to be mistaken) will be treated detrimentally as a result of making such a report.

The Company policy will be reviewed periodically to ensure continued compliance with the Bribery Act 2010 and any other applicable legislation as well as the suitability, adequacy and effectiveness of the Policy and related systems.

REMONDIS

Issue : 25.01.2017

Environmental Policy

REMONDIS JBT act as environmental partners for our customers providing a waste management service that complies with their business and legislative requirements as well as ensuring we meet all our legislative requirements. Our continuous improvement philosophy ensures that our service is dedicated to meeting current customer requirements and considers their future needs.

REMONDIS JBT are committed to:
– Recycling as much waste as we can cost effectively.

– Reducing the amount of waste sent to landfill.

– Operating a management system across all business functions that conform to the requirements of ISO 14001 and to attaining the highest possible standards of Environmental, Health and Safety and Quality performance.

– Complying with the spirit as well as the letter of environmental legislation and Codes of Practice whilst maintaining open communication with all regulatory authorities.

– Assessing the environmental effects of its policies and operations with the objective of preventing pollution, reducing environmental impact and where possible providing environmental benefits.

– Setting environmental objectives and targets.

– Seeking to influence customers and suppliers of materials and services to adopt policies that are consistent with those of the Company.

– Continually evaluating our suppliers’ environmental policies and performance.

– Conserving resources and promoting waste minimisation as well as recovery of energy and recycling of materials where appropriate.

– Evaluating new techniques that will provide benefit to the environment.

– Educating and motivating our workforce to minimize environmental impacts of daily work.

Our Environmental Policy is continually monitored and reviewed to ensure that it meets the environmental objectives and targets of REMONDIS JBT and remains relevant and effective to the changing needs of our business, customers and legislation

REMONDIS

Issue 6: 19.10.2018

Equal Opportunities

REMONDIS JBT is an equal opportunity employer and is committed to a policy of treating all its employees and job applicants equally.

It is the policy of the Company to take all reasonable steps to employ and promote employees on the basis of their abilities and qualifications without regard to race, religion, colour, sex, national origin, disability, age or sexual orientation.

REMONDIS JBT will appoint, train, develop and promote on the basis of merit and ability alone.

Employees have a duty to co-operate with the Company to ensure that this policy is effective to ensure equal opportunities and to prevent discrimination. Disciplinary action will be taken against any employee who is found to have committed an act of improper discrimination. Serious breaches of the equal opportunities policy will be treated as gross misconduct.

Employees must not harass or intimidate other employees on the grounds of race or sex, disability, age or sexual orientation. Such behaviour will be treated as gross misconduct in accordance with the disciplinary procedure.

Employees should draw the attention of their immediate superior to suspected discriminatory acts or practices.

Employees must not victimise or retaliate against an employee who has made allegations or complaints of sex or racial discrimination, or discrimination on the grounds of disability, age or sexual orientation, or provided information about such discrimination. Such behaviour will be treated as gross misconduct in accordance with the disciplinary procedure.

Employees should support colleagues who suffer such treatment and are making a complaint.

REMONDIS

Issue 2: 25.01.2015

Health & Safety Policy

REMONDIS JBT is committed to:
Working in partnership with its employees and stakeholders to meet and exceed their responsibilities under occupational health and safety legislation and guidelines relevant to the company, and aims to prevent injury and ill health by continually reviewing working procedures and practices.
Providing sufficient resources and equipment to ensure that the Company can operate to the documented management system across all business functions that conforms to the requirements of BS OHSAS 18001 and is appropriate to the nature and scale of the Companies occupational health and safety risks. The management system will provide a framework for the setting and reviewing of occupational health and safety objectives.
Ensuring that all employees are made aware and understand this policy statement and their individual occupational health and safety obligations. To this end, employees must be fully committed to health and safety to protect themselves, other employees and others who may be affected by their activities. Following company procedures and work instructions is an integral part of the employee’s responsibilities under this policy
Communicating to all subcontractors employed by REMONDIS JBT or any other interested parties of the requirements of this health and safety policy that they shall be required to meet the same objectives in all respects.
Conducting risk assessments of all appropriate activities as well as fully documenting and implementing measures to achieve satisfactory control.
Ensuring that all personnel are trained to the highest of standards for any duties they are required to perform, and eventualities that may arise as detailed on the company risk assessments.
Communicating to all that Health and Safety is paramount and con-tributes to the success of the business.
Ensuring that REMONDIS JBT will take all reasonable measures to protect the health and safety of employees and all others who may be affected by our activities.
Continually improving its occupational health and safety management system and company performance in health and safety. Our health and safety policy is monitored and reviewed to ensure that it meets the company’s legislative requirements, health and safety objectives and targets and remains relevant and effective to the changing needs of our business and customers.

REMONDIS

Issue 8: 30.10.2018

Quality Policy

REMONDIS JBT is committed to:
Raising the profile of the Company in the waste and recycling industry, increasing the market share regionally, increasing our customer base and retaining our existing customers. This will be achieved by responding to their requirements for good service, innovative waste solutions and high quality recycled products.
Sustaining employment for existing and future staff, providing a good place to work and developing staff to ensure that the Company has the necessary skills to meet all current and future challenges and to ensure a professional, effective and friendly service is given to our clients. This demonstrates to our staff that they are recognized as key to the company’s overall performance.
Forging partnerships with our suppliers, stakeholders and major players in the private and public sectors to ensure optimum business performance. We also ensure that our suppliers and partners that may be used in the delivery of our services also comply with our quality philosophy and company policies.
Achieving and maintaining a standard of excellence in the operation of our plant.
Maintaining our reputation for honesty and integrity and ensuring that this is reflected throughout the organisation from top to bottom.
Providing sufficient resources and equipment to ensure that the Company can operate to the documented Management System. The management system conforms to the requirements of BS EN ISO 9001, the International Standard for Quality Management Systems, BS EN ISO 14001, the International Standard for Environmental Management Systems and BS OHSAS 18001 Occupational Health & Safety Management System.
Ensuring that our quality management system provides a framework for the management and control of our activities for Quality, Environment and Health & Safety. It also assists in establishing and reviewing strategic objectives for the company.
Ensuring that all Company policies & procedures have the full support of senior management.
Continually monitoring and reviewing our Quality Policy is to ensure that it remains relevant and effective to the changing needs of our customers.
Continuous appraisal of our business to ensure that the quality of service we provide fully and consistently meets our customer expectations and all current and impending legislative requirements.

REMONDIS

Issue 6: 19.06.2017

Human Trafficking and Modern Slavery Prevention Policy

This policy statement sets out the steps taken by REMONDIS JBT to prevent modern slavery and human trafficking, as far is reasonably possible, in its business and supply chain. By following this policy, REMONDIS JBT seeks to meet the responsibilities of Companies under the Modern Slavery Act 2015.

Modern slavery is a crime and can take many guises but its simplest definition is: any form of enforced or coerced labour breaching an individual’s basic human rights. The Directors of REMONDIS JBT believe that the only way to stop this from happening is to be transparent in their hands on approach to tackling this global issue. This policy therefore has their full support and commitment.

REMONDIS JBT has added this policy to its audited management system, which follows the principles of continuous improvement and will therefore regularly review the Company’s performance against this policy statement, setting new SMART objectives each time. This is to further reduce the risk of Human Trafficking and Modern Slavery occurring in any part of its operations.

A link to this policy can be found on our website. It is also included in employee handbooks and displayed in head office of REMONDIS JBT as well as on employee notice boards to encourage transparency and highlight the importance of following the policy.

The policy is to be applied to all persons, at all levels, working for or with the Company whether they are employees, directors, contractors, agents, interns, volunteers, external consultants, third party representatives or business partners.

MEASURES TAKEN WITHIN REMONDIS JBT

To prevent modern slavery occurring within our own work force we have several key policies and procedures which form part of our continuous improvement management system:

– Recruitment policy which involves right to work checks being carried out for all new employees or individuals offered a role within REMONDIS JBT.

– We have a robust bullying and harassment policy which is communicated to all our staff in their employee handbook and have an open door policy to all levels of management so that any concerns an employee has can be addressed quickly and confidentially.

– We also carry out risk assessments to protect vulnerable groups of employees such as those who are classed as young workers, apprentices or those here with us on work experience.

By primarily recruiting directly we have greater control in ensuring none of our own employees have been forced into labour and have the right to work in the UK. On the occasions we use recruitment agencies, due diligence is carried out on the agency and we only use approved reputable recruitment agencies.

REMONDIS JBT also follows the Rethman Group Corporate Compliance Policy which can be found through our website.

MEASURES WITHIN OUR SUPPLY CHAIN

As part of the REMONDIS JBT management system all potential suppliers are audited to assess whether they meet the standards we require. This includes assessing whether they are taking reasonable steps to prevent human trafficking and modern slavery. Once a satisfactory audit result is obtained they are placed on our approved supplier list. This list is reviewed annually and any non-conformances by suppliers are investigated to assess whether they should remain on the approved list.

As we know that not all our suppliers will be required to publish modern slavery statements we work with them, especially our smaller suppliers, to ensure that they have minimised the risk of modern slavery occurring amongst their workforce.

The areas covered in a supplier audit are:

  • Bullying and harassment procedures;
  • Health and Safety procedures and record;
  • Environmental procedures and record;
  • Whistleblowing and ethics procedures.

Our supply chain mainly consists of subcontracted UK hauliers, large plant and equipment manufacturers and suppliers of overhead resources such as utilities and office supplies. If we become aware that anyone in our supply chain has been involved in human trafficking or modern slavery whether knowingly or through failing to take all steps to prevent it, they will be removed from our approved supplier list and will have to wait a minimum of 6 months before being able to reapply to be an approved supplier. They will also have to demonstrate that they have improved their policies and procedures to ensure that the breach which allowed modern slavery to happen has been rectified.

RESPONSIBILITY FOR POLICY ADHERENCE

Although all employees are expected to adopt and promote this policy the ultimate responsibility lies with the board of directors of REMONDIS JBT.

REMONDIS

Issue 3: 28.01.19

INFORMATION SECURITY MANAGEMENT POLICY

REMONDIS JBT operates from two sites in the North East of England, our head office in Bedlington, Northumberland and our secondary site in Birtley, County Durham. Customers cover a range of business sectors throughout the North East of England, including industrial and commercial businesses, local authorities as well as small businesses and households. REMONDIS JBT manage waste streams including industrial and commercial and construction and demolition waste, in addition to the accepting of WEEE directive.

REMONDIS JBT operates established quality, environmental and health and safety policies and is accredited to ISO 9001, ISO 14001 AND BS OHSAS 18001. These standards are incorporated into an Integrated Management System, which sets out operating procedures and standards that the business follows. REMONDIS JBT is committed to achieving standards of excellence and continuous improvement in the operation of its site.

PURPOSE
The purpose of this Information Security Example Policy is to provide exemplar guidance in line with best practice for the production of an Information Security Policy appropriate for REMONDIS JBT.

SCOPE
The production of an Information Security Policy for systems, devices or applications and information deployed in support of REMONDIS JBT business functions.

APPLICABILITY
This Policy is applicable to and designed for use by any company that use or have access to REMONDIS corporate systems and/or information at any level.

 

POLICY
The Information Security Policy outlines the approach, methodology and responsibilities for preserving the confidentiality, integrity and availability of REMONDIS JBT information. It is the overarching Policy for information security and supported by specific technical security, operational security and security management policies. It supports the 10 data security standards. This Policy covers:  Information Security Principles.  Governance – outlining the roles and responsibilities.  Supporting specific information security policies – Technical Security, Operational Security and Security Management.  Compliance Requirements.

INFORMATION SECURITY PRINCIPLES
The core information security principles are to protect the following information/data asset properties:  Confidentiality (C) – protect information/data from breaches, unauthorised disclosures, loss of or unauthorised viewing.  Integrity (I) – retain the integrity of the information/data by not allowing it to be modified.  Availability (A) – maintain the availability of the information/data by protecting it from disruption and denial of service attacks. In addition to the core principles of C, I and A, information security also relates to the protection of reputation; reputational loss can occur when any of the C, I or A properties are breached. The aggregation effect, by association or volume of data, can also impact upon the Confidentiality property.

For REMONDIS JBT, the core principles are impacted, and the effect aggregated, when any data breach relates to customer data.

GOVERNANCE – ROLES AND RESPONSIBILITIES
All Staff
Information Security and the appropriate protection of information assets is the responsibility of all users and individuals are expected at all times to act in a professional and responsible manner whilst conducting REMONDIS JBT business. All staff are responsible for information security and remain accountable for their actions in relation to REMONDIS JBT and customer information and information systems. Staff shall ensure that they understand their role and responsibilities, and that failure to comply with this Policy may result in disciplinary action. This will be reinforced by yearly mandatory training.
Senior Information Risk Owner
The Senior Information Risk Owner (SIRO) is accountable for information risk within REMONDIS JBT and advises the Board on the effectiveness of information risk management across the organisation. Operational responsibility for Information Security shall be delegated by the SIRO to the REMONDIS JBT Information Security Officer.

All Information Security risks shall be managed in accordance with the REMONDIS JBT Risk Management Policy.
Chief Information Security Officer
The Chief Information Security Officer is responsible for the day to day operational effectiveness of the Information Security Policy and its associated policies and processes. The Information Security Officer shall:  Lead on the provision of expert advice to the organisation on all matters concerning information security, compliance with policies, setting standards and ensuring best practice.  Provide a central point of contact for information security.  Ensure the operational effectiveness of security controls and processes.  Monitor and co-ordinate the operation of the Information Security Management System.  Be accountable to the SIRO and other bodies for Information Security across REMONDIS JBT.  Monitor potential and actual security breaches with appropriate expert security resource

The Data Protection Officer is responsible for ensuring that REMONDIS JBT and its constituent business areas remain compliant at all times with Data Protection, Privacy & Electronic Communications Regulations, Freedom of Information Act and the Environmental Information Regulations. The Data Protection Officer shall:  Lead on the provision of expert advice to the organisation on all matters concerning the Data Protection Act, compliance, best practice and setting and maintaining standards.  Provide a central point of contact for the Act both internally and with external stakeholders (including the Office of the Information Commissioner).  Communicate and promote awareness of the Act across the REMONDIS JBT.  Lead on matters concerning an individual’s right to access information held by REMONDIS JBT and the transparency agenda.

Information Asset Owners
The Information Asset Owners (IAOs) are senior/responsible individuals involved in running the business area and shall be responsible for:  Understanding what information is held.  Knowing what is added and what is removed.  Understanding how information is moved.  Knowing who has access and why.

Senior Responsible Owners
All Senior Managers, Heads of Department, Information Risk Owners and Directors, defined as Senior Responsible Owners (SROs), are individually responsible for ensuring that this Policy and information security principles shall be implemented, managed and maintained in their business area. This includes:  Appointment of Information Asset Owners (IAO) to be responsible for Information Assets in their area(s) of responsibility.  Awareness of information security risks, threats and possible vulnerabilities within the business area and complying with relevant policies and procedures to monitor and manage such risks  Supporting personal accountability of users within the business area(s) for Information Security  Ensuring that all staff under their management have access to the information required to perform their job function within the boundaries of this Policy and associated policies and procedures.

SUPPORTING PRINCIPLES
The Information Security Policy is developed as a pinnacle document which has further policies, standards and guides which enforce and support the Policy. The supporting policies are grouped into three areas: Technical Security, Operational Security and Security Management and are shown in the diagram overleaf. The Information Security Policy is closely aligned to REMONDIS JBT’s Data Privacy Policy and relies upon, and supports, REMONDIS JBT’s Security policies.

TECHNICAL SECURITY
The technical security policies detail and explain how information security is to be implemented. These policies cover the security methodologies and approaches for elements such as: network security, patching, protective monitoring, secure configuration and legacy IT hardware and software.

OPERATIONAL SECURITY
The operational security policies detail how the security requirements are to be achieved. These policies explain how security practices are to be achieved for matters such as: data handling, mobile & remote working, disaster recovery and use of social media.

SECURITY MANAGEMENT
The security management practices detail how the security requirements are to be managed and checked. These policies describe how information security is to be managed and assured for processes such as: information security incident response, asset management and auditing.

LEGISLATION
REMONDIS JBT is obliged to abide by all relevant UK and European Union legislation. The requirement to comply with this legislation shall be devolved to employees and agents of REMONDIS JBT, who may be held personally accountable for any breaches of information security for which they may be held responsible. REMONDIS JBT shall comply with all relevant legislation appropriate; this includes but is not limited to:  Data Protection Act 2018  General Data Protection Regulation 2018  Freedom of Information Act 2000  Computer Misuse Act 1990

AUDIT
Audit will be performed as part of the ongoing REMONDIS JBT Audit Programme and the Information Security Officer shall ensure appropriate evidence and records are provided to support these activities at least on an annual basis.

REVIEW
This Policy shall be reviewed at least annually by the reviewers noted within the Reviewers section of this Policy. The Information Security Officer shall be responsible for ensuring the review is conducted in good order and follows due process for approval. The Information Security Officer is accountable for providing the results of ongoing reviews of information security implementation across REMONDIS JBT.

 

REMONDIS

 

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