Policies

Policies – Effective 01 April 2022 

Canongate Communications Limited (Trading as The Business)  

1. Equalities & Diversity 
2. Bribery and Corruption 
3. Copyright  
4. Cyber Security 
5. Modern Slavery 

1 – EQUALITIES AND DIVERSITY POLICY  

Canongate Communications Limited (Trading as The Business) is committed to encouraging equality and diversity among our workforce and preventing and eliminating any unlawful discrimination that may arise.  

The aim is for our workforce to be truly representative of all sections of society and our customers, and for each employee to feel respected and able to give their best. The organisation – in providing our goods and services is also committed against unlawful discrimination of customers or the public.  The aim of this Policy is to: 

• Provide equality, fairness, and respect for all in our employment, whether temporary, part-time, or full-time. This includes free lace and part time staff and those we engage in supporting roles at our conferences and events.   
• Not unlawfully discriminate because of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality, and ethnic or national origin), religion or belief, sex (gender) and sexual orientation. We work towards representing this within our magazines and conferences.  
• Oppose and avoid all forms of unlawful discrimination. This includes in pay and benefits, terms, and conditions of employment, dealing with grievances and discipline, dismissal, redundancy, leave for parents, requests for flexible working, and selection for employment, promotion, training, or other developmental opportunities.   
• Encourage equality and diversity in the workplace as they make good practice and make business sense.  
• Create a working environment free of bullying, harassment, victimisation, and unlawful discrimination, promoting dignity and respect for all, and where individuals’ differences and the contributions of all staff are recognised and valued. 
• This commitment includes training employees about their rights and responsibilities under this equality policy. Responsibilities include staff conducting themselves to help the organisation provide equal opportunities in employment, and prevent bullying, harassment, victimisation and unlawful discrimination.  
• All staff should understand they, as well as their employer, can be held liable for acts of bullying, harassment, victimisation, and unlawful discrimination, in the course of their employment, against fellow employees, customers, suppliers and the general public.  
• Take seriously complaints of bullying, harassment, victimisation and unlawful discrimination by fellow employees, customers, suppliers, visitors, the public and any others during the organisation’s work activities.  
• Such acts will be dealt with as misconduct under the organisation’s grievance and/or disciplinary procedures, and any appropriate action will be taken.   
• Particularly serious complaints could amount to gross misconduct and lead to dismissal without notice.  
• Further, sexual harassment may amount to both an employment rights matter and a criminal matter, such as in sexual assault allegations.   
• Make opportunities for training, development, and progress available to all staff, who will be helped and encouraged to develop their full potential, so their talents and resources can be fully utilised to maximise the efficiency of the organisation.  
• Decisions concerning staff being based on merit (apart from in any necessary and limited exemptions and exceptions allowed under the Equality Act).  
• Review employment practices and procedures when necessary to ensure fairness, and also update them and the policy to take account of changes in the law.  
• Monitor the make-up of the workforce regarding information such as age, gender, ethnic background, sexual orientation, religion or belief, and disability in encouraging equality and diversity, and in meeting the aims and commitments set out in the equality policy.  
• Monitoring will also include assessing how the equality policy, and any sporting action plan, are working in practice, reviewing them annually, and considering and taking action to address any issues.  
• The equality policy is fully supported by The Company Director and all senior staff.   

2 – ANTI-BRIBERY AND CORRUPTION STATEMENT    

Canongate Communications Limited (The Business) is committed to conducting business ethically as well as complying with all applicable laws.  This includes compliance with anti-bribery and anti-corruption laws such as the UK Bribery Act 2010.  

The purpose of this document is to set out our stance in relation to bribery and corruption.  This statement applies to all consultants, agents, sales reps, associated third parties and contractors of Canongate’s within all regions, areas and functions. Canongate’s policy on bribery and corruption is as follows:  

• Canongate has a zero-tolerance policy towards bribery and corruption. 
• Canongate’s staff and others working on our behalf must not offer, promise, or give a bribe to anyone, and must not request, agree to accept, or take a bribe from anyone.  
• Canongate has in place measures to maintain its high ethical standards and protect its reputation against any allegations of bribery and corruption.  It is Canongate’s policy to compete fairly. We want to win business because of the quality and competitiveness of our products and services. We will not attempt to win on any other basis. We seek to positively influence others wherever practical by setting an example and openly refusing to undertake or support bribery as a way of doing business anywhere the world.  

Bribery is a crime, and penalties can be severe, including prison sentences and large financial penalties.  The UK Bribery Act 2010 applies to The Business and those performing services on its behalf. It not only makes paying or taking a bribe illegal, i.e. the person who pays or takes a bribe has committed a crime, but also holds UK companies liable for failing to prevent bribery by those working on its behalf, even indirectly (such as through non-UK subsidiaries, agents, sales reps, contractors, suppliers and intermediaries) unless the company can prove it had adequate procedures in place to prevent bribery. Recognising bribery and corruption; a bribe could involve:  

• The direct or indirect promise, offer, authorisation, or provision of anything of value.  
• The offer or receipt of any kickback, loan, fee, commission, reward, or other advantage. 
• The giving of contributions or donations designed or stipulated to influence the recipient to act in the giver’s favour.  
• The purpose of a bribe is often to obtain, retain or “facilitate” business, where the person receiving the bribe is, or may be, in a position to provide that kind of business advantage to the party offering the bribe.   
• This may involve sales initiatives, such as tendering and contracting; or, it may simply involve the handling of administrative tasks such as licences, customs, taxes or import/export matters.   
• It does not matter whether the act of bribery is committed before or after the tendering of a contract or the completion of an administrative task.  

The party offering or receiving a bribe might be: 

• An employee, officer, or director.  
• Any person acting on behalf of Canongate (e.g., third party suppliers or agents);  
• Individuals and organisations representing Canongate that authorise someone else to carry out these acts.  

Bona fide hospitality and promotional or other business expenditure, which seeks to promote our brand, to better present products and services, or to establish cordial relations, is recognised as an established and important part of doing business.  

Hospitality, entertainment, or other business expenses provided to business partners and customers for these purposes are permitted, if they are reasonable and proportionate, and are not intended to influence the outcome of any business transaction. Hospitality, entertainment, or other similar expenses are not permitted if:  

• It might influence the outcome of a business transaction, whatever the value of the expense, or a reasonable individual could interpret it that way.  
• It is for the purpose of facilitating or expediting any decision to award new business, to renew existing business or to take any other action.  
• It is given for personal benefit, friendship, personal acquaintances, or family purposes.  

The giving or receiving of gifts (or otherwise personal preferential treatment) by Canongate staff or third parties acting on our behalf must never:  

• Be used to obligate, or appear to obligate, the recipient.  
• Be of cash, cash vouchers, certificates with a set negotiable value, or other cash equivalents.  
• Be sought or requested from any person or organisation.  

Canongate will not facilitate the evasion of tax by a customer, supplier or other third party, including government officials and contractors, by making payments to offshore bank accounts, or by other means, which have no commercial basis or could be construed by tax authorities to be made to facilitate tax evasion by the recipient.  

If you are aware of any Canongate related non-compliance with this statement, you can report it to The Company Director.  

3 – COPYRIGHT POLICY 

All the material and content that is published on this website is protected by copyright law. Use that is made without our permission may infringe our copyright which can result in personal and corporate liability.   

When we state within this Policy that something is not allowed or permitted then to do so is a breach of our terms and conditions and may violate copyright law. What you may do: 

• View our content for your personal use on any device and store that content for personal use only and not for academic or business purposes.  
• Print single copies of articles for your personal use only and not for academic or business purposes.  
• Publish the original headline and a link to the article on The Business.com.  
• Forward the original headlines and links to other individuals.  

What you may not do:  

• Imply that The Business are endorsing your products or services.  
• Re publish or redistribute articles into other news aggregators, media, websites or newsletters creating the impression that it may not have originated from The Business.  
• Full reference to the source with links must be always used.  
• Photocopy any articles for distribution in hard format without a license from The Newspaper Licensing Agency. 

4 – CYBER 

This policy addresses the handling of sensitive, personal, and confidential information held by the Company and is reviewed regularly. All staff are aware of its existence and contribute to its development.  

In order to demonstrate our commitment to Cyber Security to our staff and customers we are working towards the UK Cyber Essentials Cyber accreditation via the SBRC and are currently going through the pre assessment procedures.  

• We check our employees ID references, and right to work and cyber security is covered at employee inductions and training offered. We have a standard starters and leavers process.  
• We use third parties to host and process customer information and conduct due diligence against these third parties for their cyber risks and ensure they properly address security and data handling.  
• This includes our CRM administrators HubSpot, virtual event platforms such as Eventsair and the EICC, magazine and newspaper printers and their fulfilment agents and Royal Mail Business services.  
• We manage access to our key systems such as Microsoft 365 and users who have privileged access are reviewed on a regular basis.  

5 – MODERN SLAVERY AND HUMAN TRAFFICKING   

This statement is in compliance with Section 54 of the Modern Slavery Act 2015 and is intended to fulfil the legal requirement for a slavery and human trafficking statement for all The Business brands. 

• For the purposes of this statement, slavery and human trafficking is based on the definitions set out in the Modern Slavery Act 2015.   
• We recognise that slavery and human trafficking can occur in many forms, forced labour, child labour, domestic servitude, sex trafficking and workplace abuse. It can include the restriction of a person’s freedom of movement, whether that be physical or non-physical.   
• We endorse all endeavours to improve the lives of others, and support opportunity for all. We are opposed to abuses of a person’s freedoms whether they work within our organisation, or our supply chains.   

We have third party product suppliers, and service providers who supply goods and services to The Business and the different business segments.  They include but are not limited to design and information technology providers; professional service providers; event management specialists; print; property and facilities. They vary both in terms of size and amount spent with them.   

• In keeping with our commitment to act with integrity in all our business dealings, we will ensure that there is no slavery or human trafficking in any part of our business or our supply chains.   
• Except for paper, print where we have access to third party policies, our other suppliers, are typical of a micro communications business – where we familiar with our suppliers, their staff, and their working practises.   
• Our products are government and public sector facing. We market our products mainly in Scotland and the United Kingdom and are a micro business with 0-10 employees. See the main segments of our business below:  
• The newspaper and magazine segment consists of publishing magazines and newspaper supplements that are distributed with newspapers titles in Scotland and via our networks.  
• Our live events are created from our offices in Edinburgh and are delivered at The Edinburgh International Conference Centre, The Sheraton Edinburgh, and our Dynamic Earth in Edinburgh.   
• The technical and content of the website originates and is delivered by our staff from our Edinburgh office.  
• Although these suppliers are self-employed individuals or SME’s they are aware that they have to meet both The Business’s expectations and legal obligations in respect of the Modern Slavery Act 2015 and agree to do so before engagement and on an ongoing basis.  
• The Business’s ethical business practices and policies protect workers from being abused and exploited, either within the company itself or within its supply chain.   
• We ask employees to contact The Company Director if they have any concerns about working conditions either in their department or one of their department’s suppliers.    

The risk of slavery and human trafficking within The Business is avoided because of these policies and working practises, and the knowledge and skills of our employees.   

• We are also protected by the nature of the business we operate in, the geography of the suppliers we engage with, all of which are currently UK based. Suppliers staff are professionally or vocationally qualified and we engage with our suppliers and their employees via social media platforms such as LinkedIn and they are all personally known to us.  
• We never engage writers or speakers who whose views personally represent a position that might be in breach of, or in any way might be construed as non-compliant to Section 54 of the Modern Slavery Act 2015.  

Policies & Statements: Effective 01 April 2022