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					                     ADELAIDE INSURANCE SERVICES LTD


           EMPLOYEE HANDBOOK




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      The purpose of this Handbook is to provide you with information in relation to the terms
      and conditions of employment and working arrangements which apply when working with
      Adelaide Insurance Services Ltd. Every care has been taken to ensure that contents are
      accurate and understandable.

      While the policies and procedures within the Handbook itself form part of your overall terms
      and conditions of employment, they are not to be construed as forming a fixed part of your
      contract as they may change over time.

      The Company reserves the right to amend the contents of this Handbook in line with any
      changes in Company policy and procedure or legislative changes. However, the handbook
      is reviewed on a regular basis and all employees will have access to the latest publication
      from the Company’s central internal reference area or online at
      http://www.adelaideinsurance.com/ais-employee-handbook

      You are advised to familiarise yourself with the contents of the Handbook as unfamiliarity
      will not excuse individuals from failure to follow its guidelines and provisions.

      Any questions or concerns in relation to the Handbook should be addressed to your Manager.




                                                             Last updated: July 2011


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The contents of this Handbook include information:


      About Adelaide Insurance Services Ltd

      Part 1          Working with Adelaide Insurance Services Ltd

      Part 2          Leave Policies

      Part 3          Disciplinary and Grievance Procedures

      Part 4          Health, safety and security policies

      Part 5          I.T. & Facilities Policies

      Part 6          Recruitment and Performance Policy

      Part 7          Other Policies

      Appendices



In addition to this Handbook, employees should also be aware of:

Z:\REGULATION, COMPLIANCE & TRAINING\Training\Training material\Procedure & policy
emails from management to Internal Mail Group in the Training folder of our internal reference area.


For Compliance requirements, refer to:

..\..\..\REGULATION, COMPLIANCE & TRAINING\Compliance\Compliance Manual Dec09.doc


For Administration on Specific policies, refer to user guides:
      Private Car: ..\..\..\INSURERS, PRODUCT PROVIDERS & PARTNERS (excluding
accounts)\PRIVATE CAR (not insurer specific)
      Household: ..\..\..\INSURERS, PRODUCT PROVIDERS & PARTNERS (excluding
accounts)\HOUSEHOLD (not insurer specific)


      Motorcycle: ..\..\..\INSURERS, PRODUCT PROVIDERS & PARTNERS (excluding
accounts)\MOTORCYCLE (not insurer specific)


For Complaints procedure, refer to

..\..\..\REGULATION, COMPLIANCE & TRAINING\Complaints\AIS Internal Complaint Handling
Procedures - Sep11.doc
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Contents:
About Adelaide Insurance Services Ltd ...................................................................... 9
  History: ............................................................................................................................................... 9
  Ownership structure: ......................................................................................................................... 9
  Objective & Focus:............................................................................................................................. 9
  Our Customers: .................................................................................................................................. 9
  Culture and brand values: ............................................................................................................... 10
  Staff Structure: ................................................................................................................................. 12
Part 1 Working with Adelaide Insurance Services ................................................. 13
  Probation: ......................................................................................................................................... 13
  Salary: ............................................................................................................................................... 13
    Payment of Salary .......................................................................................................................... 13
    Salary Deductions .......................................................................................................................... 13
    Salary Reviews ............................................................................................................................... 14
    Tax Issues ...................................................................................................................................... 14
  Hours of Work: ................................................................................................................................. 14
    Normal hours .................................................................................................................................. 14
    Daily working .................................................................................................................................. 14
    Breaks ............................................................................................................................................ 15
    Record of hours of Work ................................................................................................................. 15
    Punctuality ...................................................................................................................................... 15
  Overtime (where applicable) ........................................................................................................... 15
  English Speaking Company ............................................................................................................ 16
  Holidays ............................................................................................................................................ 16
  Staff Benefits .................................................................................................................................... 17
    Staff Incentive scheme ................................................................................................................... 17
    Life Assurance ................................................................................................................................ 20
    Pension Scheme ............................................................................................................................ 20
    Retirement ...................................................................................................................................... 20
    Company Health Insurance Plan .................................................................................................... 21
    Private Health Insurance ................................................................................................................ 21
    Insurance Discounts ....................................................................................................................... 21
  Notice to terminate employment..................................................................................................... 21
  Change of Address .......................................................................................................................... 21
Part 2          Leave Policies ............................................................................................. 22
  Absence from Work ......................................................................................................................... 22
  Sickness Benefit Scheme ................................................................................................................ 23
    Payments ....................................................................................................................................... 23
    Notification of Sickness .................................................................................................................. 24
    Statutory Sick Pay (SSP) ................................................................................................................ 24
    Return to Work ............................................................................................................................... 24
    Fitness Notes.................................................................................................................................. 25
  Medical Appointments ..................................................................................................................... 26
  Adverse Weather Policy .................................................................................................................. 26
  Maternity Policy................................................................................................................................ 26
    Policy Statement............................................................................................................................. 26
    Time off for antenatal care .............................................................................................................. 26
    Maternity Leave .............................................................................................................................. 27
    Maternity Pay.................................................................................................................................. 27
    Company Maternity Benefits .......................................................................................................... 27
    Timing of maternity leave ............................................................................................................... 28
    Notification ...................................................................................................................................... 28
    Payment of Statutory Maternity Pay ............................................................................................... 28
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    Keeping in touch days .................................................................................................................... 29
    Returning to work after maternity leave .......................................................................................... 29
    Rights during maternity leave ......................................................................................................... 30
    Health and safety............................................................................................................................ 30
    Maternity leave timetable ................................................................................................................ 31
  Parental Leave Policy ...................................................................................................................... 32
    Who is entitled to Parental Leave? ................................................................................................. 32
    What are the provisions of Parental Leave? ................................................................................... 32
    Notice of Intention to take Parental Leave: ..................................................................................... 33
    Postponing Parental Leave on the basis of Business Needs: ........................................................ 33
    Refusing / Terminating Parental Leave .......................................................................................... 34
    Employees’ Rights regarding Parental Leave ................................................................................. 34
    Disputes and Appeals:.................................................................................................................... 34
    Special Note: Parental Leave for children receiving a disability living allowance .......................... 35
  Adoptive Parents.............................................................................................................................. 35
    Eligibility ......................................................................................................................................... 35
    Length of adoption leave ................................................................................................................ 35
    Statutory Adoption Pay ................................................................................................................... 36
    Notice of intention to take adoption leave ....................................................................................... 36
    Matching Certificate ........................................................................................................................ 36
    Contractual benefits........................................................................................................................ 36
    Return to work after adoption leave ................................................................................................ 36
  Paternity Leave................................................................................................................................. 37
    Policy statement ............................................................................................................................. 37
    Ordinary paternity leave for the birth of a child ............................................................................... 38
    Ordinary paternity leave for the adoption of a child within the UK .................................................. 38
    Ordinary paternity leave for the adoption of a child from overseas ................................................. 39
    Statutory paternity pay during ordinary paternity leave ................................................................... 40
    Rights during ordinary paternity leave ............................................................................................ 40
    Returning to work after ordinary paternity leave ............................................................................. 40
    Additional paternity leave for the birth of a child ............................................................................. 41
    Additional paternity leave for the adoption of a child within the UK ................................................ 42
    Additional paternity leave for the adoption of a child from overseas ............................................... 44
    Additional paternity pay .................................................................................................................. 45
    Rights during additional paternity leave .......................................................................................... 46
    Returning to work after additional paternity leave ........................................................................... 46
  Flexible Working .............................................................................................................................. 47
    Who can ask for flexible working? .................................................................................................. 47
    Scope of a request ......................................................................................................................... 47
    Procedure ....................................................................................................................................... 48
    Procedure following application ...................................................................................................... 48
    Calculation of the start of the period of 28 days ............................................................................. 49
    Notification of the decision .............................................................................................................. 49
    Appeals .......................................................................................................................................... 49
    Extension of the time limits ............................................................................................................. 50
    Withdrawal of application by an employee ..................................................................................... 50
    Grounds for refusal ......................................................................................................................... 51
  Time off for Dependants .................................................................................................................. 51
  Force Majeure ................................................................................................................................... 52
  Compassionate Leave ..................................................................................................................... 52
  Jury Service ...................................................................................................................................... 52
Part 3        Disciplinary and Grievance Procedures ...................................................... 54
  Disciplinary Procedure .................................................................................................................... 54
    Purpose and scope......................................................................................................................... 54
    Principles ........................................................................................................................................ 54
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    Procedure ....................................................................................................................................... 54
    Stage 1 – Verbal Warning .............................................................................................................. 54
    Stage 2 – Written Warning ............................................................................................................. 55
    Stage 3 – Final written warning ...................................................................................................... 55
    Stage 4 – Dismissal ........................................................................................................................ 55
    Serious misconduct ........................................................................................................................ 55
    Gross misconduct ........................................................................................................................... 56
    Appeals .......................................................................................................................................... 57
  Grievance Procedure ....................................................................................................................... 57
    Stage 1 ........................................................................................................................................... 58
    Stage 2 ........................................................................................................................................... 58
    Stage 3 ........................................................................................................................................... 58
Part 4        Health, safety and security policies ............................................................. 59
  Health & Safety Policy Statement ................................................................................................... 59
    Policy and Statement...................................................................................................................... 59
    Application ...................................................................................................................................... 60
    Statement of Responsibilities ......................................................................................................... 60
  Use of Workstation .......................................................................................................................... 61
  Health and Safety guidelines for the pregnant employee ............................................................ 62
  Manual Handling .............................................................................................................................. 63
  Fire / Evacuation .............................................................................................................................. 63
  Risk Assessment ............................................................................................................................. 65
  First aid / accidents.......................................................................................................................... 65
  Litter / general cleanliness .............................................................................................................. 65
  Smoking policy................................................................................................................................. 66
  Consumption of Alcohol / Drugs .................................................................................................... 66
  Staff Conduct at Christmas Parties and Social Outings ............................................................... 66
  Dignity and respect in the workplace ............................................................................................. 67
    Introduction ..................................................................................................................................... 67
    Commitment to dignity and respect in the workplace within Adelaide. ........................................... 67
    Harassment .................................................................................................................................... 67
    Bullying ........................................................................................................................................... 68
    Legislation ...................................................................................................................................... 68
    What should you do about harassment or bullying? ....................................................................... 68
    Procedure ....................................................................................................................................... 69
    Informal Procedure ......................................................................................................................... 69
    Formal Procedure ........................................................................................................................... 69
    What should you do if you are accused of harassment or bullying? ............................................... 71
    Malicious or vexatious claims ......................................................................................................... 71
    Management responsibility ............................................................................................................. 71
    Individual responsibility ................................................................................................................... 71
  Equality through diversity ............................................................................................................... 71
    Introduction ..................................................................................................................................... 71
    Managing diversity.......................................................................................................................... 71
    Workplace discrimination and the law ............................................................................................ 72
    Recruitment, selection and promotion ............................................................................................ 72
    Career and personal development ................................................................................................. 72
    Performance review and feedback ................................................................................................. 73
    Use of language / illustrations in internal and external group documents ....................................... 73
    Combining work and life responsibilities ......................................................................................... 73
    Breaches of the policy .................................................................................................................... 73
Part 5                 IT & Facilities policy .............................................................................. 74
  Computer Use Policy ....................................................................................................................... 74
   Scope and Objectives..................................................................................................................... 74
   Responsibilities of staff ................................................................................................................... 74
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    Hardware / Software ....................................................................................................................... 75
    Copying of Software ....................................................................................................................... 75
    Passwords ...................................................................................................................................... 75
    Storage of Files / Housekeeping..................................................................................................... 76
    Virus Controls ................................................................................................................................. 76
    Data Protection ............................................................................................................................... 76
  Internet / Email Policy ...................................................................................................................... 76
    Introduction ..................................................................................................................................... 76
    Scope ............................................................................................................................................. 77
    Policy Objectives ............................................................................................................................ 77
    Internet Security ............................................................................................................................. 77
    Internet Legislation ......................................................................................................................... 77
    Internet and e-mail access control .................................................................................................. 77
    Out of Office Assistant .................................................................................................................... 78
    Internet – Standards of Use ............................................................................................................ 80
    E-mail – Standards of Use .............................................................................................................. 81
    Use of Internet and Social Network sites by employees ................................................................. 82
  Control & Protection of Confidential Information ......................................................................... 83
    Confidential Information Clause ..................................................................................................... 83
  Media Policy ..................................................................................................................................... 83
    Comments to Press/Media ............................................................................................................. 83
  Personal Property ............................................................................................................................ 83
  Clear Desk Policy ............................................................................................................................. 84
  Security of Office, Office Property, Money .................................................................................... 84
    Boucher Plaza Security .................................................................................................................. 84
    Office Security ................................................................................................................................ 84
    Wastage policy ............................................................................................................................... 85
    Money............................................................................................................................................. 85
    Important Documents & Cover Note Books .................................................................................... 85
  Car-Parking Facilities ...................................................................................................................... 85
  Office Telephones ............................................................................................................................ 86
  Mobile Phone Usage ........................................................................................................................ 86
Part 6          Recruitment and performance policy ........................................................ 87
  Equal Opportunity Policy – Fair Employment ............................................................................... 87
    Policy .............................................................................................................................................. 87
    Responsibilities............................................................................................................................... 87
  Employment of Relatives ................................................................................................................ 87
    Guidelines ...................................................................................................................................... 88
    Other Relationships ........................................................................................................................ 88
  Performance Reviews ...................................................................................................................... 88
    Purpose and scope of the Performance Development Policy ......................................................... 88
    Outline of Performance Development System ................................................................................ 88
    Procedures ..................................................................................................................................... 89
  Opportunities & Progression .......................................................................................................... 89
  Lay-Off / Short-Time......................................................................................................................... 89
  Redundancy ..................................................................................................................................... 90
Part 7          Other policies .............................................................................................. 91
  Intellectual Property......................................................................................................................... 91
  Communications .............................................................................................................................. 92
    Department Meetings ..................................................................................................................... 92
    Management Meetings ................................................................................................................... 92
    Notice Boards ................................................................................................................................. 92
    Message taking .............................................................................................................................. 92
  Dress Code ....................................................................................................................................... 92
  Secondary Employment .................................................................................................................. 93
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  Business Expenses ......................................................................................................................... 93
  Business Gifts .................................................................................................................................. 93
  Speaking-Up Policy and Procedure................................................................................................ 94
    Introduction ..................................................................................................................................... 94
    Users Guide ................................................................................................................................... 94
    Policy .............................................................................................................................................. 95
    Pre Procedure ................................................................................................................................ 96
    Policy .............................................................................................................................................. 96
    General........................................................................................................................................... 97
  Bribery .............................................................................................................................................. 98
  Car Use ............................................................................................................................................. 98
  Company Vehicle Use ...................................................................................................................... 98
    Prohibited Uses .............................................................................................................................. 98
    Authorised drivers........................................................................................................................... 99
    Driving Licence ............................................................................................................................... 99
    Material Facts and Information ....................................................................................................... 99
    Penalties for Offences .................................................................................................................... 99
    Insurance ........................................................................................................................................ 99
    Windscreen Damage, Theft Claims and Damage......................................................................... 100
    Service Maintenance and Repairs ................................................................................................ 100
    Expenses ...................................................................................................................................... 100
    Absences from work ..................................................................................................................... 101
Appendices ................................................................................................................ 102
  Appendix 1 - Maternity notification .............................................................................................. 102
  Appendix 2 - Variation to maternity leave start date ................................................................... 103
  Appendix 3 - Notification of early return from maternity leave .................................................. 104
  Appendix 4 - Ordinary paternity leave self certificate (birth of child) ........................................ 105
  Appendix 5 - Ordinary paternity leave self certificate (UK adoption) ........................................ 106
  Appendix 6 - Ordinary paternity leave self certificate (overseas adoption) .............................. 107
  Appendix 7 - Ordinary paternity leave - change of start date form............................................ 110
  Appendix 8 - Additional paternity leave employee’s notice and declaration (birth) ................ 111
  Appendix 9 - Additional paternity leave mother’s declaration (birth) ........................................ 112
  Appendix 10: Additional paternity leave employee’s notice and declaration (UK adoption) .. 113
  Appendix 11 - Additional paternity leave adopter’s declaration (UK adoption) ....................... 114
  Appendix 12: Additional paternity leave employee’s notice/declaration (overseas adoption)115
  Appendix 13: Additional paternity leave adopter’s declaration (overseas adoption) .............. 116
  Appendix 14: Additional paternity leave - change of start date form ........................................ 117
  Appendix 15: Notification of early return from additional paternity leave ................................ 118
  Appendix 16 - Form FW (A) Flexible Working Application Form ............................................... 119
  Appendix 17 - Form FW (B) Flexible Working Application Acceptance Form .......................... 122
  Appendix 18 - Form FW(C) Flexible Working Application Rejection Form ............................... 123
  Appendix 19 - Form FW (D) Flexible Working Appeal Form ....................................................... 125
  Appendix 20 - Form FW (E) Flexible Working Appeal Reply Form ............................................ 126
  Appendix 21 - Form FW (F) Flexible Working Extension of Time Limit ..................................... 127
  Appendix 22 - FW (G) Flexible Working Notice of Withdrawal Form ......................................... 128
  Appendix 23 - Notice to Employer of Force Majeure Leave ....................................................... 129
  Appendix 24 - Internal Job Application Form .............................................................................. 130
  Appendix 25 – Adelaide Insurances Bribery Policy .................................................................... 132




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About Adelaide Insurance Services Ltd

History:

Adelaide Insurance Services was founded in December 1991, as part of the Charles Hurst Group (the leading
Northern Ireland motor group). Charles Hurst recognised that being able to provide insurance to their customers
would be an advantage whilst selling new and used cars and motorcycles. They already had relationships with
many insurance companies since their foundation in 1911 through their large body-shop handling vehicle
repairs.

Charles Hurst therefore began developing these relationships and transacted business through the formation of
a subsidiary company, Adelaide Insurance Services. Adelaide’s role was to provide an insurance brokerage for
the group’s dealerships, i.e. Nissan, Renault, Citroen and Rover. Adelaide implemented some ‘free insurance’
schemes and was the first insurance company to successfully develop and market ‘3 Years Insurance’ within the
United Kingdom.
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Ownership structure:

In 1996, the Charles Hurst Group was sold to Lookers plc and Adelaide was bought by Woodchester Investment
Brokers (part of Woodchester Finance). Woodchester Brokers became Cornmarket Group Financial Services
Ltd in 1998 – a subsidiary of Irish Life and Permanent plc. Cornmarket own 100% of the equity of Adelaide.
Since January 2008, Irish Life & Permanent plc own 100% of the equity of Cornmarket.
For Group Corporate Structure, see: Z:\HR -PERSONNEL\Employment\Staffing Structure diagrams\IL&P Group
Structure -Operational Jan09.pdf
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Objective & Focus:

Adelaide restructured in 1997 turning our focus to Affinity Groups and niche markets namely:

      Motorcyclists
      Teachers, Leaders & Managers in Education
      Advanced Drivers & Riders

The objective was to increase customer service and provide quality private car, home and motorcycle insurance
supported by a panel of insurers who could offer this.

On 1 July 2000, Adelaide moved to our own premises at Boucher Plaza, Boucher Road, Belfast. With employee
capacity increasing over time, we expanded & refurbished our offices in May 2006 and also again in May 2011
as the workforce have increased. IT hardware and capacity needs were also upgraded resulting in Adelaide
becoming a “paperless” office.

Voted “UK’s Favourite Motorcycle Insurance broker” for 2008
Adelaide Insurance was voted ‘the UK’s Favourite Motorcycle Insurance broker’ for 2008. This annual “Rider
Power Survey”, conducted by the renowned “RIDE” magazine claims to be the largest survey of its kind in the
world, with over 8,000 people surveyed. We achieved first place for customer service and scored the top rating
for claims handling and won the overall number 1 ranking. This is an achievement considering we’d only been in
the UK-wide market since 2006 and were up against well established UK companies.

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Our Customers:

Motorcyclists - we’ve been providing motorcyclists with insurance since 1992 in Northern Ireland, expanding
UK wide in 2006 and then into the Republic of Ireland in 2007. Adelaide is recognised as the leading providers
of motorcycle insurance in N.I.



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I.N.T.O - The Irish National Teachers’ Organisation – we’ve been providing their members with preferential
car and home insurance as their official insurance provider since 1997.

U.T.U. - The Ulster Teachers’ Union – we’ve been providing their members with preferential car and home
insurance since 2005.

AMiE – Association of Managers in Education – In May 2008, we were appointed the official insurer for AMiE,
the leading trade union and professional association for leaders and managers in schools and colleges across
the UK.

Women’s Institute – since January 2011 Adelaide have been providing preferential car and home insurance for
members of the Women’s Institute and their spouses and partners.

I.A.M. – The Institute of Advanced Motorists – since Adelaide set up an insurance scheme for IAM members
in May 2005 the relationship developed rapidly, culminating in Adelaide being appointed the IAM’s sole UK
insurance provider for members’ personal insurance in October 2007. Adelaide’s trading name under which they
administer the scheme is ‘IAM Surety’.

IAM Family – from the large success of the IAM, in February 2010 Adelaide set up a scheme which offers car,
home and motorcycle insurance to immediate family of IAM members.

L.N.W.A – London Neighbourhood Watch Association – Adelaide was appointed by the LNWA in June 2011
to provide home and car insurance to their members.

LGV /HGV Drivers (Large Goods Vehicles /Heavy Goods Vehicles) – since October 2011 Adelaide have been
providing these members with preferential car and home insurance.
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Culture and brand values:

Adelaide has always striven to be socially responsible in the conduct of our business.

BikeSafe - We’ve been actively involved in road safety since 1997 when we began working with the Police
Service of Northern Ireland to promote BikeSafe, which provides a critical appraisal of motorcyclists’ riding skills
through a short, free assessment of ability in key areas. Many bikers who successfully complete the BikeSafe
assessment go on to complete the IAM safety assessment and Adelaide reward bikers who successfully
complete either of these assessments with further discounts on their insurance.

Roadwise – aimed primarily at young car drivers, Roadwise driver training and test was conceived in 2003,
developed and administered by Adelaide. This safety programme is aimed at 17 to 24 year old car drivers.
Once these drivers have successfully completed the Roadwise test, they’re normally entitled to preferential rates
on their car insurance with Adelaide. To ensure the development of Roadwise across the UK, all rights and
administration of courses was taken over by the IAM.

“The Dominic Fox Award” – Adelaide was awarded this award in 2004 by the IAM for our major contribution to
road safety.

“Safety Award” at the Irish Racer Awards in Northern Ireland - sponsored by Adelaide since 2005. This award
recognises those who’ve made substantial contributions to road safety each year.

Advanced driver training for Adelaide staff – Adelaide encourage all staff that drive a car to complete their
advanced training and sit their IAM test.

Global Schoolroom
Global Schoolroom is sponsored by Adelaide Insurance Services Ltd and Cornmarket Group Financial Services
Ltd and supported by the Association of Secondary Teachers Ireland (ASTI), the Teachers Union of Ireland (TUI)
and Irish National Teachers Organisation (INTO). Now in partnership with University College Dublin, Global
Schoolroom offers an accredited Diploma in Teacher Education to teachers in the Developing World who

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complete the programme. Teachers from Ireland and the UK travel with Global Schoolroom each year to deliver
the programme in 10 centres in North East India and 2 in Uganda over the summer.

Business in the Community Award
Adelaide received the prestigious ‘BIG TICK’ Award from Business in the Community in 2011
Out of hundreds of entries in 2011, Adelaide was honoured in the UK’s leading awards for road safety
programmes.
Adelaide is among a small group of businesses to receive Business in the Community’s (BITC) coveted National
Big Tick for our “motorcycling and young driver road safety initiative programmes”
The Big Tick award recognises inspirational programmes that are making a positive impact on the community,
the environment or wider society.



Charities Supported:

 - R.N.L.I.
 - Marie Curie – Adelaide staff and customers raised £53,000 for Marie Curie Cancer Care by raffling a Harley
   Davidson motorcycle in their centenary year, the same year that Marie Curie won her Nobel Prize.
 - Children in Need
 - Down Syndrome Ireland
 - Ireland Air Ambulance
 - Movember 2011 – Men’s Health.
 - Salvation Army – Christmas Toy Appeal.
 - Transplant Sports UK – Adelaide staff participated in the Belfast Marathon in May 2011 to fundraise money
   for the Transplant Sports UK charity.
 - Cash for Kids – Bring a Pound to Work.
 - Wear it Pink – Breast Cancer Campaign.
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Staff Structure:




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Part 1                 Working with Adelaide Insurance Services
                                       Tumble out of bed and stumble to the kitchen;
                                               pour myself a cup of ambition,
                                       and yawn, and stretch, and try to come to life.
                                     Jump in the shower, and the blood starts pumping;
                                        out on the street, the traffic starts jumping,
                                       with folks like me on the job from nine to five.
                                                    Dolly Parton – 9 To 5


Probation:

The statutory probationary period is 12 months.

All new employees must undergo a review after a minimum period of 6 months, during which your Manager will
review your performance. Your Manager will take account of various factors related to your job performance
including your progress and capabilities, your timekeeping, absence, conduct and disciplinary record. At the
conclusion of your review period, your line manager will report to senior Management with recommendations.

If the Company considers that a different review period is required from the beginning of your employment, this
will be specified in your Offer Letter.

It may sometimes be necessary to extend the review period and the Company may extend your review period for
a further period at the discretion of management. If your review period is to be extended, you will be informed,
and given the reason for this.

If the Company have agreed to a salary increase at the end of the review period, this will be specified in your
Offer Letter including the amount of increase.

The review period will not be extended beyond the statutory 12 months probationary period.

At the end of the 12 month probationary period, provided that you and the Company are satisfied, you will be
informed in writing confirming entitlement to full employment terms and benefits.

During the probationary period the disciplinary procedure does not apply.

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Salary:

Payment of Salary

Salaries are paid monthly in arrears on the 28th day of the month, or if the 28th falls on a non-banking day (e.g. a
Saturday, Sunday or bank holiday) the Company will aim that you receive your pay on the banking day before
28th. Payment is made directly into your bank account by credit transfer. Employees should provide the
Company’s payroll processor with new bank details in good time in advance of this date.
New employees who start employment in the latter half of the month, after the salary payment file has been
prepared, will not usually receive pay that month for work completed during that month, but will receive any
payment due in the following month.
Each month you will receive a payslip detailing your salary, tax and National Insurance deductions and any other
payment details.
Payments for overtime (including Saturday work) and any incentive/bonus payments will be paid in the following
month.

Salary Deductions

In addition to tax and National Insurance deductions in your monthly pay, deductions may also be made for:
  - Unpaid absence (see Leave section);
  - Holidays taken, but not yet earned (see Holiday section);
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 -   Pension (see Pension section);
 -   Company Health Plan (see Company Health Plan section)
 -   £4 for use of kitchen supplies provided for use by all staff, eg tea, coffee, milk, sugar, filtered water.

Salary Reviews

Salaries are revised annually in January at the absolute discretion of the Company. Generally all employees are
included in the review, except those on probation or those who are not performing to the required standard.

It is Adelaide’s policy to reward effort where it has been demonstrated. Your salary is therefore reviewed
annually, entirely at Adelaide’s absolute discretion. It does not follow that employees can expect an increase
every year, as many factors need to be considered (such as individual, team and company performance, and
other competitive industry sectors). Management will take account of your conduct, responsibilities and general
performance during the year. Any salary increase usually takes effect from 1st January and will be notified to you
in writing.

Tax Issues

Your tax position is personal to you. If you have any queries we recommend that you contact the tax office
directly at the following address:-

 HMRC
 PAYE
 PO Box 1970
 Liverpool
 L75 1WX

The phone number is 0845 300 0627.

Please quote the company tax reference (925/71578) and your National Insurance number.

You should advise the tax office of a change of address, marital status or any change in your benefits.

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Hours of Work:

Normal hours

Normal hours of work are:      39.5 hours per week for most full-time employees;
                               (Unless otherwise agreed in writing);
                       Plus:   3.5 hours on alternate Saturday mornings;
                               (Unless otherwise agreed in writing)
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Daily working

Daily working hours may vary although will generally be between:
                            9:00am and 5:30pm, Monday to Thursday;
                            9:00am to 5:00pm, Friday;
                            9:00am to 12:30pm, Saturday (where applicable);

but will be dictated by the demand of the business, or such hours as are necessary for the satisfactory execution
of your duties. Adelaide’s working hours will at all times comply with the Working Time Regulations (NI), 2009,
as amended and accompanying regulations. This also provides for:

                           -   Maximum 48 hour week (subject to opt-out agreements)
                           -   Daily rest – 11 hours in each 24 hour period
                           -   Weekly rest – 24 hours in each 7 day period
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Breaks

Refer to your contract of employment regarding paid and unpaid breaks. Most full-time employees receive a 10
minute paid break in the morning and another mid afternoon at the Company’s discretion. Most full-time
employees are entitled to a 30 minute unpaid lunch break. You should refer to your department head before
taking a break.
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Record of hours of Work

For the purposes of monitoring employees’ hours worked, attendance, timekeeping, etc., you are required to
‘swipe-in’ at the ActinTime console immediately upon entering the office to attend for work each day.

There are two ActinTime consoles situated within the two offices – one in the sales office and one in the
administration office. In the sales office it is located at the front of the office beside the fire exit door; and in the
administration office it is located to the right hand side when entering through the double doors.

If you arrive for work later than your usual agreed start-time, or forget to ‘swipe-in’ immediately upon entering the
office, you must advise your department head or manager so that he/she may sign-off your attendance and
advise those processing payroll.

Employees are required to ‘swipe-out’ at the beginning of their lunch break and then at the end of their lunch
break ‘swipe-in’ as they return to their work.

You must also ‘swipe-out’ at the end of your working day.
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Punctuality

Adelaide will use appropriate means to record attendance. Punctuality is a key job requirement for every
Adelaide employee and lateness will not be tolerated.

Staff are expected to be at work at least 5 minutes before their normal start time, so as to be ready to start work
on time, and in the case of a 9:00am start – attend a daily briefing at 8:55am. Break times, especially returning
from breaks on time must also be strictly adhered to. Returning from lunch/dinner at any time later will only be
allowed after prior authorisation by management.
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Overtime (where applicable)

On occasions, due to the fluctuating demands of the business or performance of individual departments, there
may be a requirement for you to be available to work overtime to meet these needs. The level of overtime to be
worked will be kept to a minimum and must be sanctioned in advance by your Department Manager with at least
one hour’s notice. Where it is necessary for staff to work overtime, as much notice as possible will be given.

Normal pay and payment of overtime is as follows:

Flat hourly rate:       -       During normal contracted weekly working hours;
                        -       For hours worked when the office is open on a Saturday morning if this is outside
                                your normal contract;
                        -       For extra time worked which is less than three hours, after normal contracted
                                working hours; or under one hour after normal Saturday opening hours.

Double time:            -       For hours worked outside your normal contracted weekly working hours when a
                                minimum of 3 hours is worked.

Payment of overtime does not apply to the following:
2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                                 Page 15 of 138
                       -       Supervisors or Managers;
                       -       Where staff are working extra time and they would have owed or would normally
                               owe time (e.g. to compensate where they have worked fewer hours in a period
                               than normal contract).

Additionally payment of overtime does not apply to:
                      -       Attendance of out-of-hours social events (e.g. customer conventions, charity
                              support events, guest entertainment, staff outing, etc.)

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English Speaking Company

Verbal and written communication between Adelaide Insurance and any other party (customers/employees) will
use the English language.
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Holidays

Holidays are important. They help recharge batteries and avoid stress. Adelaide will wish to ensure that Staff
avail of their full holiday entitlement.

This clause has contractual effect.

The holiday year for Adelaide Insurance Services runs from 1st January to 31st December.

During the first two years of employment, you will accrue leave at the rate of one twelfth of annual entitlement for
each complete month worked. Leave may normally only be taken after it has accrued. Where leave requested
exceeds leave accrued, and your Manager allows the leave, only the accrued leave will be paid. The remaining
period will be unpaid, until you have worked sufficient time to accrue the leave.

Holiday entitlement is on a pro-rata basis and is dependent on your length of service as follows:

        Up to 5 years service:         22 days
        After 5 years service:         23 days
        After 10 years service:        24 days
        After 15 years service:        25 days
        After 20 years service :       26 days

Any increase in entitlement applies in the holiday year after you have achieved the relevant length of service.
Discretion may be applied by management.

In addition:

       Full-time employees are entitled to paid leave on Public Holidays recognised in Northern Ireland. If
        Adelaide requires you to work on a public holiday, prior consultation will take place and a day off in lieu of
        the public holiday will be agreed. You will only be entitled to be paid for Public Holidays if you have
        worked at least 40 hours in the previous 5 weeks ending on the day before the Public Holiday.

       Part-time employees are entitled to have a pro-rata entitlement to paid leave on Public Holidays
        recognised in Northern Ireland. If Adelaide requires you to work on a public holiday, prior consultation
        will take place and a day off in lieu of the public holiday will be agreed. You will only be entitled to be
        paid for Public Holidays if you have worked the pro rata equivalent of 40 hours in the previous 5 weeks
        ending on the day before the Public Holiday.

All holidays should be taken during the holiday year and there is no provision for payment in lieu of holidays
unless you are leaving Adelaide. Likewise holidays cannot be accrued and carried forward into the next year.



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All holidays should be agreed in advance with your Manager. You must obtain the prior written (email)
permission of your manager before committing yourself to bookings or any alternative positive arrangements.
Holiday requests will normally be considered on a ‘first-come, first-served’ basis. Where two or more holiday
requests are received at or around the same time, in respect of the same period of leave, seniority and length of
service will be taken into account. Priority (where suitable) will also be given to requests from staff wishing to
arrange leave involving advance booking of travel arrangements. Please consult your Manager as soon as
possible.

Before submitting a holiday request, staff are expected to have checked the Staff Leave calendar and look at all
the factors which Department Heads and managers will consider when granting holidays e.g. clashes with other
team members with similar duties, especially for periods of anticipated high business volume.
The outlook Staff Leave Calendar is assessable to all staff members. To view it, go to your outlook calendar,
Open a Shared Calendar and select Staff.Leave.calendar.

Holiday requests are submitted by email using template ..\..\..\GENERAL REFERENCE\Blank Forms\Holiday
Request.doc and sent to their manager. Upon receipt of staff holiday requests, managers will then reply
accordingly by completing the corresponding sections. If the holiday is granted the staff leave calendar will be
updated and the holidays added on.

To assist management in planning adequate Staff cover, you will be expected to take your holiday allocation as
follows:
        1 week in a block during the 1st quarter of the year, i.e. between mid-January and 31st March. Requests
        for this leave are to be received by your manager by mid-January. Due to start of year increases in
        workload, holidays will not normally be allowed during the first 2 weeks of January.
        2 weeks in a block during 2nd and 3rd quarters of the year, i.e. between 1st April and 30th September.
        Requests for this leave will not normally be accepted until 15th March, unless accompanied by proof of
        holiday arrangements.
        1 week in a block during the 4th quarter of the year, i.e. from 1st October to 31st December. Requests for
        this leave will not normally be accepted until 15th September.
        Any remaining ‘floating’ days may be used at any time during the year (subject to manager approval).
You will be expected to provide a minimum of 1 month’s notice in respect of a block of 2 weeks leave, and for
other leave a minimum of 1 week’s notice.

Holiday entitlement accrues at the rate of one twelfth of annual entitlement per month. In the holiday year in
which your employment commences or terminates your holiday entitlement will be calculated on a pro-rata basis
(rounded to the nearest complete day) for each complete month worked.

In special circumstances, such as a new employee being committed to holiday arrangements before joining
Adelaide, your Manager may authorise appropriate additional leave, which will normally be unpaid.

Holiday entitlement will not accrue during extended absence or absences on sick leave in excess of the
equivalent of 4 weeks in a holiday year (pro rata for part-time workers).

Adelaide may require you to take any outstanding accrued holiday entitlement during your notice period.
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Staff Benefits

Staff Incentive scheme

Adelaide Insurance Services Ltd currently run an Incentive Scheme designed to reward staff for:

       the achievement of individual or team performance against monthly targets;
       sales with an instalment facility (sales staff);

2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                           Page 17 of 138
       good customer feedback scores for the team;
       satisfactory levels of administration (for Sales Admin and for Sales Advisors);
       proper completion of duties, and compliance with standards and house rules.

Incentive payments are offered at the discretion of the management in addition to basic employee remuneration
and may be subject to alteration at any time.

The scheme is offered to most employees (after satisfactory completion of initial training, normally 3 months),
and penalties may be levied by management for failure to comply with:
Adelaide Insurance Services – Housekeeping Rules                    (the latest copy will be displayed in the
kitchen notice board)

Below is a summary of our main rules for good ‘Housekeeping’. Breaches may lead to penalty on incentives and
disciplinary proceedings where appropriate.

General:
       No Smoking policy: Smoking is strictly prohibited in the office, including toilets. There are no ‘smoke-
        breaks’. Smoking is only permitted in normal break /lunch times; and must not be in front of the
        premises. Staff may smoke at the rear & side of the building and must ensure that all butts are disposed
        of appropriately. Staff are not permitted to smoke near the rear entrance/exit doors.
       Timekeeping: all staff are expected to be at work at least 5 minutes before their normal start time.
       All staff vehicles should be parked to the rear of the building.
       Company Dress Code must be adhered to at all times.
       Chewing gum is not permitted in the office, and gum must not be dropped on the ground anywhere at
        Boucher Plaza.
       No persons (other than Adelaide or Cornmarket employees) are to be admitted to the main office unless
        they have signed in.

Office Tidiness & Data Protection:
       Clear workstation policy – ensure your desk is clear of all paperwork and stationery at the end of each
        day. Desk tops overnight should only contain a monitor, phone, and scanner.
       There should be no overnight storage of paperwork /stationery /boxes underneath desks, on window sills
        or chairs. Client-related paperwork must be placed in an organised manner in the storage units located
        near each department, and the storage units must be closed at the end of each day.
       All staff are expected to ensure the office is kept as tidy as possible. Each member of staff who attends
        the Customer Counter must ensure it is tidy when they leave. Documentation left by customers must be
        removed from the counter as soon as possible.
       All paperwork for shredding must be deposited into a locked shredding cabinet at the end of day.
       The stationery storage area must be kept tidy – all empty boxes should be flattened and thrown out
        immediately.
       Access to the lift, upstairs and downstairs, from all offices -must be kept clear of obstructions.
       Ensure the exit door in the conference room is locked at all times.
       All overcoats should be hung on the coat-hooks provided, not over the back of chairs. All handbags
        should be stored below desks during work hours.

I.T. Security & Equipment:
       Breach of Computer Use and Internet & Email policy can pose a serious risk to the entire network and will
        be treated accordingly. No personal internet /e-mail use is permitted at your own PC. The stand-alone
        PC at the rear of the office is provided for this purpose outside your normal working hours.
       PCs must be Shut Down at the end of each day.
       PCs must be ‘Locked’ when leaving your desk.
       If you have a scanner which can be switched off by closing the lid, you must do so each day to preserve
        the life of the scanner. Do not set documents in your scanner if not being scanned.

Kitchen:
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        All food/drinks must be removed from the fridge at the end of the day. The fridge should only be used for
         the overnight storage of milk and items supplied for general use.
        All cutlery and crockery must be washed, dried and put away immediately after use.
        Before heating items in the microwave which may splash/spill, you must cover the item with Clingfilm.
        Kitchen windows should be opened if cooking smells may arise when using the microwave.
        All spillages on the counter /table /floor should be cleaned immediately.
        The bins must be emptied when full - blue bin for rubbish and green bin for recycling items.
        The blue paper-towel roll must be replaced on the holder when finished.
        All newspapers must be disposed of at the end of day.
        Worktops and tables are to be kept clean, dry and tidy after use – they are not to be sat on for hygiene
         reasons.

Toilets:
        You must leave the toilet as you would wish to find it.
        You must replace the toilet roll, hand soap and handtowels when empty.
        You must not throw hand towels down the toilet.
        Lights have been installed above the two toilet doors in the sales office. If the light is lit ‘green’ the toilet
         is occupied. If the light is out the toilet is vacant.

Other:
        Personal mobile phones should be switched to ‘silent’ during working hours.
        Personal calls should not be made on the business lines during work.
        Switch off all fans at the end of day.
        ‘Bin Duty’ and ‘Milk Duty’ are normally rotated weekly. The person who is on ‘bin duty’ must ensure all
         bins (including the bins in the kitchens and toilets) are changed when required. If a bin is full, change it,
         even if you are not on the rota. Ensure there is an adequate supply of milk in the fridge.
        When you are the last person to use the last copy of a common document /piece of stationery, e.g.
         Counter Sign-Off sheet, Terms of Business booklets, ensure you reprint more or arrange a re-order.
        All incoming faxes must be passed to the appropriate person and not placed in the tray used to store fax
         reports.

Failure to comply with any of the above conditions will result in a deduction of 5% from your personal
Incentive for each misdemeanour. This deduction will be applied to your Incentive for that trading month or will
be applied to the next incentive payable.


Absence and incentive payments
The Company expects that staff members will make every effort to attend work each day. Absence from work
creates inefficiencies within the Company and places extra work pressure on colleagues. In the event of any
absence (other than scheduled Holiday leave, Maternity related leave, or other Leave defined in Part 2 of this
Handbook), personal penalties will apply to that trading month’s Incentive share. In addition, the amount of
Incentive paid will be reduced on a pro-rata basis according to the number of working days you have missed that
month, e.g. if you have only worked 15 out of 20 trading days that month, you will receive 15/20 of the Incentive
amount, in addition to the penalties shown below. If a period of absence extends to another trading month, this
pro-rata reduction will be applied to each affected month’s Incentive; however the penalties shown below will
only be applied once in respect of one period of absence.

         Upon 1st absence        25% personal penalty
         Upon 2nd absence        50% personal penalty, and for every absence thereafter.

If you leave
If you leave or your employment with Adelaide is ceased, no Incentive payment will be made for the trading
month you do not complete.

New Staff (During Probationary Period)


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Staff members, who fail to comply with the aforementioned standards and rules, though do not yet qualify to
receive Incentive payments, will still have each misdemeanour or absence noted.


Penalties in a month where no incentive is payable
Penalties due to be deducted in a month where an incentive payment is not achieved, will be deducted from the
next Incentive payment that is achieved. Penalties held over will not exceed 50%.

Pro-Rata payments according to hours of work
A ‘full’ monthly Incentive payment will be based on a typical full time member of staff working 165 hours/month
(based on a 4 week month, and to include an average of 2 Saturday mornings). Staff contracted to work fewer
hours will receive a pro-rata proportion. Additional overtime worked will not affect calculation of incentive.


Employee Opt In / Opt Out.
Staff eligible to be included in the Incentive Scheme will be asked to Opt In or Opt Out. This includes new
members of staff who will be eligible to join after satisfactory completion of initial training.
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‘No Absence’ Bonus
A bonus of £100 (net) will be paid to all employees who fulfil their contracted hours between January and
December each year, without having any unscheduled absences.
To qualify you must have worked for Adelaide for a minimum of six months.
The bonus will be subject to pro-rata, if by December you have not been with the Company for 12 months.
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Life Assurance
All permanent employees will be included in the Company’s Life Assurance Scheme from their first date of
joining. This provides a death-in-service benefit of three time’s basic salary.
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Pension Scheme
The Company has a pension scheme that is available to all employees who have attained 3 months’ service,
and who apply to join.
A copy of the Pension Scheme booklet is available on request from Margaret McHugh.
For further details on the scheme and how to opt in please contact:
       Pension & Financial Consultants Ltd                 [Tel: 028 9078 3030]
       PFC House
       Quayside Office Park
       14 Dargan Crescent
       Belfast
       BT3 9JP
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Retirement
From 6th April 2010 to 1st October 2011, in respect of employees approaching the age of 65, an employer can
retire employees at the age of 65 where the employer notifies the employee prior to 6th April 2011. In these
cases, your employment will terminate on the day before you attain the age of 65 years unless varied by
agreement in writing between yourself and management.

From 1st October 2011 there is no compulsory retirement age, although an employer may still request an
employee to retire in certain circumstances giving reasons.

Management may consider a phased reduction of your working hours - up to three years before your retirement
date.
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Company Health Insurance Plan

The Westfield Health Plan is available to all Adelaide employees who have attained 1 months’ service. The
plan can enable employees to recover some of the costs of certain treatments including Dental, Optical,
Therapy, and Counselling. Contributions are made by the Company. Employees have the option to increase
cover and include partners (at the employee’s expense). Limits depend on the level of contributions.
For details of policy limits refer to: Z:\GENERAL REFERENCE\Staff folders\Westfield benefits (from Dec
2010).pdf.
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Private Health Insurance
There is a Group Medical Insurance Scheme in place, which offers Private Health Insurance at a discount. You
are eligible to join the Group Scheme at your own expense.
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Insurance Discounts

Adelaide Insurance Services offers certain staff discounts for policies of insurance arranged by the Company for
the staff member and members of their immediate family. Details are available from your Manager.
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Notice to terminate employment

Employment may be terminated by either party by giving the following written notice:

      If you leave to commence employment with a competitor in the insurance industry, only one week’s
       notice need be given by either party; otherwise:
      A minimum of 2 weeks’ notice of termination.
      After five years’ service Adelaide will provide an additional one week’s notice for every year of continuous
       service up to a maximum of 12 weeks.

During your probationary period, both parties must only provide 1 week’s notice.

Adelaide reserves the right, at its discretion to pay salary in lieu of notice. In the event of Adelaide opting to
invoke this right, any such payment will be treated in the same way as standard wage procedures.

Any exceptions to the above will be specified on an individual’s contract of employment.

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Change of Address

All employees whose home and/or correspondence address changes must promptly provide the new details to:

 Margaret McHugh margaret.mchugh@adelaideinsurance.com
 Adelaide Insurance Services Ltd
 First Floor Boucher Plaza
 4-6 Boucher Road
 Belfast
 BT12 6HR

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Part 2                                            Leave Policies
                           My child arrived just the other day; Came to the world in the usual way.
                                       But there were planes to catch and bills to pay.
                                            He learned to walk while I was away.
                                               He was talking’ ‘fore I knew it.
                                    And as he grew he said, “I’m gonna be like you, Dad.
                                              You know I’m gonna be like you.”

                                                Cats In The Cradle – Harry Chapin



Absence from Work

Adelaide recognises that there are occasions when absence from work is unavoidable and Adelaide requires
staff to comply with specific procedures set out below. If an employee can’t get to work, it comes out of their
annual leave or unpaid leave (Possibility of exception for adverse weather conditions)

The management will follow the following procedure in the event of staff absence:

Frequent absence
When considering absence, the management will consider the full record of the staff member since the start of
their employment, i.e. a record of poor attendance in previous years may be taken into account in determining
action, or whether the employee is fit for certain roles within the Company.

More than 3 absences in 12 months
Where a member of staff is absent 4 times in 12 consecutive months, this will automatically result in a hearing
being held in accordance with the published Disciplinary Procedure. You may also be required to attend a
medical examination by a registered medical practitioner nominated by Adelaide.

In the interests of clarity, below is a table to show the absences which will/won’t normally count towards
disciplinary:


                    Absences which Count towards                  Absences which Don’t count disciplinary
                            disciplinary
                                                                     Holiday Leave (pre-authorised) paid or
                                  Illness
                                                                                    unpaid
                                 Accident                               Maternity Leave (paid or unpaid)
                                                                 Medical Appointments (pre-notified) with time
                              Hospitalisation
                                                                                 worked-up
                   Recovery following illness, accident,
                                                                    Time off for antenatal care (usually paid)
                 hospitalisation, treatment, operation, etc
                   Force Majeure paid or unpaid leave                   Paternity Leave (pre-authorised)
                                                                    Parental Leave (pre-authorised) usually
                   Absence due to ‘Adverse Weather’
                                                                                    unpaid
                Any other unpaid leave (not mentioned in            Adoptive Parent Leave (pre-authorised)
                            column on right)                                     usually paid
                                                                    Time off for Dependants (usually unpaid)
                                                                    Compassionate Leave – (usually paid) re
                                                                      member of immediate family or close
                                                                     relative, within leave day limit set out in
                                                                                     Handbook
                                                                                    Jury Service




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Sickness Benefit Scheme

The Company Sickness Benefit Scheme (CSBS) will apply to all employees (subject to the conditions
mentioned below) with one or more years’ service. Any employee with less than one year’s service, who meets
the Statutory Sick Pay requirements, will be paid Statutory Sick Pay (SSP) only.

All employees are required to submit themselves at any time during the course of their employment at the
request of Adelaide to a medical examination by a registered medical practitioner nominated by Adelaide. The
purpose of such medical examination shall be to determine whether there are any matters which might impair
your ability to perform your duties and accordingly you will give such authority as is required for Adelaide’s
nominated doctor to disclose to the Company the findings. All expenses associated with obtaining the report will
be borne by Adelaide.

A prolonged absence from work because of illness may result in an employee’s employment being terminated.
The decision would only be taken after a full investigation of the circumstances of the illness and after a review
of the effect of the employee’s absence from their Department. Doctors are not required to provide a Statement
for any period of sickness absence lasting 7 calendar days (5 working days) or less. As a result, employees
should self-certify as being unfit for work for the 7 calendar days (5 working days) of sickness. Employers are
entitled to ask an employee for a Statement after this seven day period.

If, in the opinion of the Company’s management, the Company Sickness Benefit Scheme is being abused
generally, Adelaide reserves the right to modify or withdraw it from employees who start employment in the
future.

Adelaide reserves the right to withhold payment of any CSBS pay if Adelaide considers you are abusing the
CSBS pay scheme and to commence proceedings under the disciplinary procedure. E.g. If management find or
witness that you were socialising away from home before returning to work after a period of absence (excluding
travelling to and from doctors, hospital, chemist, medical appointments).

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Payments

Company Sickness Benefit Payments will normally be made as follows:

       2 weeks CSBS sick pay after 1 year service
       4 weeks CSBS sick pay after 2 years service
       8 weeks CSBS sick pay after 3 years service
       10 weeks CSBS sick pay after 4 years service
       Maximum of 13 weeks CSBS sick pay after 5 years service.

These payments will be the maximum in any one year, commencing 1st January each year. 13 weeks CSBS will
be the maximum CSBS payment by Adelaide to an individual within any continuous 2 year period.

Management may, in exceptional circumstances and at its discretion, extend the number of weeks’ sick pay but
up to a period of not more than 26 weeks.

Benefit renewal anniversaries occurring on or after 1st January each year within a period of sickness absence
after benefit entitlement is exhausted will not initiate a renewal of benefit payments until a complete return to
work for a period of eight weeks by the employee concerned.

Payment under the Company Sickness Benefit Scheme will be made in respect of the first absence occurring in
a year. However, upon a second absence in a year and for each subsequent absence in a year -the first 3
days of each absence will not be paid.

To receive payment under the Company Sickness Benefit Scheme you must comply with the rules of the
CSBS including notification requirements (see Notification of Sickness) and, if required (see above) submitting to
a medical examination below. To receive payment under the CSBS you must also submit a fitness note from a
qualified doctor if the absence is for more than 5 working days.

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Consideration to any extended payment may be given at the discretion of Management.

Payments will be made up to normal take-home pay from Statutory Sick Pay entitlement during the first 13
weeks, if applicable.

The Company payment will be subject to all normal payslip deductions, including PAYE where applicable.
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Notification of Sickness

      On your first day of absence you must advise your manager as early as possible, by phone, and in any
       event no later than 9:30am of the reason for absence and its likely duration.

      You should subsequently continue to keep your manager informed about your progress towards
       recovery.

      You will be expected to update your manager on a daily basis before 9:30am by phone, unless
       Adelaide has received a valid medical certificate from a qualified doctor. If you are unable to contact your
       manager, please advise another member of the management team or in their absence you’re
       Department Head.

A Self Certification form (..\..\..\GENERAL REFERENCE\Blank Forms\Absence-SelfCertForm.pdf) must be
submitted if absence is 5 working days or less. If absence is for more than 5 working days you must submit a
‘fitness note’ from a qualified doctor. This is also required to receive payment under the CSBS. The fitness note
must state the nature of the illness and its likely duration. The fitness note must be forwarded to your Manager
promptly, who will pass it to the Personnel Department.

Further fitness notes will be required to cover the total period of absence. It is your responsibility to keep the
Company informed about your progress and your likely date of return.
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Statutory Sick Pay (SSP)

Statutory Sick Pay is the legal minimum sick pay to which you are entitled and the Company on behalf of the
Department of Social Services pays it. It is automatically paid as part of your salary if you are ill and will depend
on your earnings in the period before you become ill. SSP is payable for up to 28 weeks.

Qualifying days for SSP shall be our normal working week, i.e. Monday to Friday. These are the only days for
which SSP will be paid, and are also the only days that will count as waiting days.

Before qualifying for SSP an employee must be absent for four working days or more in a row, as the first three
days (waiting days) of sickness absence do not qualify for sickness payment, unless linked to a previous
sickness absence by 40 working days or less. This linking can only apply to sickness periods of at least 4 days.

SSP may be withheld by the Company if there is reason to believe that the employee was not ill or, subject to the
rules set out above, the employee failed to notify the Company of the absence according to the requirements of
the organisation. Adelaide reserves the right to request an employee’s attendance at a medical appointment
with a Company-nominated Doctor.
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Return to Work

You will not be permitted to return to work until your doctor has accepted that you are fit to return to work. When
you inform Adelaide you are fit to return the Company reserves the right to require you to attend a medical
examination by the Company doctor prior to you being permitted to restart work.

All employees are expected to complete a ‘Return to Work form’ and attend a ‘Return to Work’ interview to
investigate the extent of the sickness. Adelaide reserves the right to request a home visit where any illness or
condition is ‘long-term’ usually 5 or more days absent prior to employee consent.

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If an employee is off work due to ‘stress’ related issues we have the right to refer the individual to an
Occupational Health specialist to assess the individual’s health.
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Fitness Notes

The Statement of Fitness for Work, or ‘fit note’, is a Medical Statement issued by GPs (from 6th April 2010
replacing Medical Certificates or ‘sick lines’), which focuses on what an employee may be able to do at work
rather than what they cannot do.

With the fit note your GP can choose one of the two options:

     You are ‘not fit for work’
     You ‘may be fit for work’

The fit note also includes:

    More spaces for your GP to give general advice about the impact of your illness or injury
    Tick boxes for your GP to suggest, where appropriate, common ways in which Adelaide could support
     your return to work

The fit notes can still be used as evidence for why you cannot work due to illness or an injury. Fit notes are not
required until after the seventh calendar day (5th working day) of sickness. If you need to apply for benefit the
rules and processes have not changed. If your doctor has recommended that you ‘may be fit for work’ you can
still apply for benefit.

The requirements for the payment of Statutory Sick Pay have not changed. If your doctor recommends that you
‘may be fit for work’, but you and management agree that you should remain off work, you should still get
Statutory Sick Pay.

Sample of ‘fitness note’:




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2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                             Page 25 of 138
Medical Appointments

As far as possible, Staff are expected to arrange for routine appointments to visit a Doctor, Dentist, etc., outside
normal working hours. However, recognising that this may not always be possible, Adelaide will, within reason,
allow time to attend appointments such as doctors, hospital, and dentists during the working day. However,
these should be arranged to cause minimum loss of time from work. Please agree any time off work in advance
with your manager and arrange to make up the lost time.

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Adverse Weather Policy

Paid ‘Special Leave’
Paid ‘special leave’ may be granted at the discretion of management to cover an employee’s absence if they
cannot attend work due to adverse weather conditions. The employee must demonstrate efforts taken to reach
the office.
It would not be unreasonable to expect able-bodied employees to walk a reasonable distance (i.e. up to 4
miles). Weather conditions on the day in question should be taken into account.


Unpaid ‘Special Leave’
Any additional absence on each occasion may be covered by unpaid special leave or annual leave.
You should make all reasonable effort to get to work. “Up to 4 miles” not only applies to those who live within 4
miles of the office, but applies to all within this distance of a bus stop or train station or where a taxi could collect
them, or where such public transport could get them near the office. An example of ‘demonstrate efforts’ would
include – if you advise your Department Head or Manager that you believed no public transport operated in your
vicinity throughout the day, this may need to be confirmed.
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Maternity Policy

Policy Statement

Adelaide Insurance Services recognises the importance of supporting pregnant employees at work and during a
period of maternity leave. The aim of this policy is to ensure that all employees are aware of their statutory and
contractual entitlements and to ensure fair and equitable treatment in line with current legislation. (Employment
Rights (Northern Ireland) Order, 1996 as amended and accompanying regulations).

When you become pregnant you must inform the Operations Manager as soon as reasonably practicable (see
Notification).

Pregnant employees have a number of rights:
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Time off for antenatal care

All pregnant employees have the right to take a reasonable amount of paid time off work for antenatal care,
irrespective of their length of service.

In order to be entitled to take time off for antenatal care, you will be required to produce a certificate from your
doctor, registered midwife or registered health visitor, stating that you are pregnant and giving your expected
date of childbirth.

Once we have evidence that you are pregnant, you will be entitled to take reasonable time off work to attend
antenatal appointments, as advised by your doctor, registered midwife or registered health visitor.

You must also produce evidence of your appointment, such as a medical certificate or appointment card, if
requested to do so.

2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                                Page 26 of 138
Try to give your manager as much notice as possible of antenatal appointments and wherever possible try to
arrange them outside working hours or as near as possible to the start or end of the working day.

You will receive full pay for time off for antenatal care and for reasonable travelling time.

Maternity Leave

Ordinary and additional maternity leave: all pregnant employees are entitled to 52 weeks leave, 26 weeks
ordinary maternity leave and 26 weeks additional maternity leave, regardless of your hours of work or length of
service. You must take two weeks compulsory maternity leave from the date the child is born and cannot work
during that time.
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Right to return to work: women who return to work at the end of their ordinary maternity leave have the right to
return to the same job. Women who return to work at the end of their additional maternity leave have the right to
return to the same job, unless this is not reasonably practicable, in which case they have the right to be offered a
suitable alternative job under terms and conditions which are no less favourable. If a mother is returning to work
from maternity leave earlier than previously planned or later than the previously agreed date she must give
Adelaide eight weeks’ notice of when she intends to work again.
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Still birth: You can still take your Statutory Maternity Leave if your child is stillborn after 24 weeks of pregnancy
or born alive at any point of the pregnancy.
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Surrogate Parents

If you and your husband, wife or partner are having a child through surrogacy, you will not normally be eligible
for Statutory Maternity or Adoption Leave. You may be eligible for unpaid parental leave once you get a parental
order.
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Maternity Pay


Statutory Maternity Pay (SMP)

Statutory Maternity Pay (SMP) replaces your normal earnings to help you take time off around the time of birth.

To qualify for SMP pregnant employees must have worked for Adelaide full or part-time for at least 26 weeks up
to and into the 15th week before the baby’s due date (the qualifying week). You will be entitled to SMP for up to
39 weeks provided your average earnings are at least equal to the Lower Earnings Limit for NICs - £102 a week
or £442 a month for 2011-12. You must be able to provide the right paperwork confirming the pregnancy and
sufficient notice when you would like the SMP payments to start.

If you are an employee who has a visa that allows you to live and work in the United Kingdom, you may be able
to get SMP. If your visa includes the condition that you have ‘no recourses to public funds’ you may still get
SMP provided you satisfy the qualifying conditions. The qualifying conditions for SMP depend on your recent
employment and earning history.

SMP will be paid the same way and at the same time as your normal wages (28th of each month). It can be paid
for up to 39 weeks.
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Company Maternity Benefits

In addition to the maternity rights outlined above, the Company provides the following enhanced maternity
benefits to those who have attained 2 years’ service (as at the end of the 15th week before the Expected Week of
Childbirth - EWC):
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      A payment of £500 (gross) at the start of maternity leave – in the pay period which includes the first week
       of statutory maternity pay (pro rata for those who work less than 39.5 hours per week)

      A payment of £150 (gross) per month for the six months following return to work after maternity leave.
       This payment will be reduced pro rata for those who work less than 39.5 hours per week. These monthly
       payments will cease in the event of resignation during the six months following return to work after
       maternity leave.

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Timing of maternity leave

Provided you have given the Company the required notification of your pregnancy (see Notification section
below), ordinary maternity leave can commence at any time on or after the beginning of the 11th week before
your expected week of childbirth (EWC).

Leave may also commence:

      on the first day after the beginning of the 4th week before the EWC, if you are absent from work due to a
       pregnancy-related illness; or
      with the birth of your child.

In order to make administration as easy as possible, please discuss the timing of your maternity leave with your
manager as early as possible.
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Notification

In order to be entitled to take maternity leave and receive statutory maternity pay and (where applicable)
Company maternity benefits, you are required to give the Operations Manager written notification of your
intention to take maternity leave no later than the Saturday of the 15th week before your expected week of
childbirth. You must state in the notification:

      that you are pregnant
      your expected week of childbirth; and
      the date on which you intend your maternity leave to start.
      the expected return to work date

You are advised to use the maternity notification form for this purpose. This can be found in the Appendices
section of this handbook.

You must also submit a MAT B1 form, signed by your doctor, registered midwife or registered health visitor, or
other evidence of your expected date of childbirth.

If you subsequently wish to change the start date of your maternity leave, you must give 28 days’ written notice
of the revised start date. You are advised to use the variation to maternity leave start date form for this purpose.
This can be found in the Appendices section of this handbook.

Within 28 days of receiving your notice of intention to take maternity leave, the Company will write to you
confirming the latest date on which you must return to work after your additional maternity leave.

You can start your Statutory Maternity Leave any time from 11 weeks before the beginning of the week when
your baby is due. If you are off work because of your pregnancy within four weeks of the expected birth date, we
can make you start your Statutory Maternity Leave then.

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Payment of Statutory Maternity Pay

Payment of Statutory Maternity Pay (SMP) starts when your maternity leave begins.


2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                           Page 28 of 138
SMP is paid at the rate of:

      90% of average weekly pay for the first six weeks of maternity leave; and
      the standard rate of SMP (which is normally increased on an annual basis) for the next 33 weeks of
       maternity leave. The standard rate of SMP is currently £128.73 per week (from April 2011), or 90% of
       your average weekly earnings if this is less than £128.73 per week.

Employees who are not entitled to SMP may be entitled to state maternity allowance. If you do not qualify for
SMP, the Company will issue you with a form SMP1. You should then contact your local Jobcentre Plus office
for further information and details of your eligibility for maternity allowance.

SMP is treated as earnings and is therefore subject to PAYE and national insurance deductions.

Statutory Maternity Pay is not usually affected by voluntary work.

Once you become entitled to or if you are already getting SMP and then go abroad, Adelaide still pays SMP.
SMP is not affected if you go into hospital or a care home. If you are sent to prison or arrested SMP will end, but
you will be able to claim Maternity Allowance (MA).
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Keeping in touch days

An employee may not normally undertake any paid work whilst in receipt of SMP. However, under the Maternity
Leave Regulations, employees are allowed to work for up to ten “Keeping in Touch” days without losing their
right to SMP or bringing their period of maternity leave to an end. Work for this purpose includes training or
briefing sessions designed to help employees to keep up to date with developments during their absence. Any
such “Keeping in Touch” days will be by agreement between you and the Company. You are not obliged to work
on any “Keeping in Touch” days if you do not wish to do so and the Company is not obliged to offer you any such
days.

If an employee works their tenth ‘Keeping in Touch’ day and then a further day’s work in the same week, she will
lose SMP for that week. This is because she will have exceeded the ten days maximum in that week. In the
Maternity Pay Period, a week means any period of seven days. For example, if your SMP started on a Tuesday,
a week will run from the Tuesday to Monday.

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Returning to work after maternity leave

New mothers are prohibited from working or returning to work for two weeks after childbirth. This is referred to
as compulsory leave.

With the exception of the compulsory leave period, you may return to work at any time during your maternity
leave period. Alternatively, you may take your full period of maternity leave entitlement and return to work at the
end of this period.

While you are on maternity leave, you have no need to notify the Company if you intend to return to work on the
due day at the end of your additional maternity leave. However, if you wish to return early, before the end of
your additional maternity leave, you must give at least 8 weeks’ notice in writing to the Company of the date on
which you intend to return. If you fail to do this, the Company may postpone your return. You are advised to use
the notification of early return from maternity leave form for this purpose. This can be found in the Appendices
section of this handbook. If you wish to return to work earlier you must inform us that;

    you are returning to work earlier

    you want to change the date of your return




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If for any reason, you are unable to return to work by the end of your additional maternity leave, you should
contact the Company immediately. Failure to return to work on the due date may be treated as an unauthorised
absence.

If you are unable to return to work because of illness, you must submit a medical certificate before the end of
your maternity leave period. If you claim Statutory Sick Pay (SSP) the normal rules for eligibility will apply. If you
are not entitled to SSP, you may be able to claim Employment and Support Allowance. Adelaide will provide you
with a SSP1 form to explain why you are not entitled to SSP.

If you decide during maternity leave that you do not wish to return to work, you should give written notice of your
resignation to the Company as soon as possible and in accordance with the terms of your contract of
employment.
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Rights during maternity leave

During ordinary and additional maternity leave, your contractual terms and conditions (with the exception of
remuneration) are preserved.
Holiday entitlement will be accrued during the whole of your maternity leave. Employees are encouraged to take
any outstanding holidays due to them before the commencement of ordinary maternity leave. Please discuss
this with your manager at the earliest opportunity.
If you are a member of the Company’s pension scheme, contributions will continue while you are receiving
statutory maternity pay. The employer contribution will continue at the usual percentage of your normal basic
monthly salary, while your contribution will be calculated as a percentage of your actual monthly pay.
Other non-pay company benefits which apply to you, such as life cover, private health insurance, will continue
during the whole of your maternity leave.
However, your salary will be replaced by SMP, if you are eligible to receive it.
The Company is entitled to make reasonable contact with you during your maternity leave.

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Health and safety

Please refer to Part 4- Health, safety and security policies of this handbook for details on ‘Health and safety
for the pregnant employee’.

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2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                            Page 30 of 138
Maternity leave timetable

What to do when you are pregnant

Please note that this plan is for guidance purposes so that you can notify the Company your intentions.

    Time                                   Notes                                 Action

1   At least 15 weeks before your          By this time, you should have         Complete the Maternity Notification
    expected week of childbirth.           received a MAT B1 certificate         form and send it together with your
                                           from your doctor or midwife           MAT B1 certificate to The Operations
                                           confirming your expected week         Manager, Adelaide Insurance
                                           of childbirth.                        Services.
                                                                                 If you later change your mind about
                                                                                 the date you want your maternity
                                                                                 leave to start, complete the Variation
                                                                                 to Maternity Leave Start Date form
                                                                                 and send it to The Operations
                                                                                 Manager, Adelaide Insurance
                                                                                 Services, giving 28 days’ notice of
                                                                                 the new date.


2   11 weeks before the expected           Maternity leave cannot start
    week of childbirth.                    earlier than the 11th week
                                           before the expected week of
                                           childbirth, unless the birth occurs
                                           sooner.


3   Two weeks after the birth.             This is the earliest date after the
                                           compulsory leave period that
                                           you can return to work.


4   After compulsory leave period          If you intend to return to work       Complete the Notification of Early
    but before the end of additional       before the end of your additional     Return from Maternity Leave form
    maternity leave.                       maternity leave, you must give        and send it to The Operations
                                           the Company at least eight            Manager, Adelaide Insurance
                                           weeks’ written notice.                Services.

                                                                                 If you decide, now or later, that you
                                                                                 do not want to return to work, you
                                                                                 must write to the Company giving
                                                                                 your contractual notice of the
                                                                                 termination of your employment.


5
    52 weeks’ absence.                     This is the last date when you        If you are unable to return to work,
                                           can return to work.                   contact the Company immediately to
                                                                                 explain why. If you are ill, you must
                                                                                 send in a medical certificate.


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Parental Leave Policy

It is Company policy to adhere to the provisions of the Employment Rights (Northern Ireland) Order, 1996 as
amended & accompanying regulations. Details of the Company’s Parental Leave policy are given below.

Scope:           This Policy covers Adelaide Insurance Services personnel with at least one year’s continuous
                 service.

Objective:       To define the level of entitlement and facilitate consistent administration.

Policy:          It is Company policy to adhere to the provisions of the Employment Rights (Northern Ireland)
                 Order, 1996, and any amendment to the Order.
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Who is entitled to Parental Leave?

You have the right to parental leave if you:

         have worked continuously for the Company for one year

and you:

         are a parent named on the child’s birth certificate; or
         are named on the child’s adoption certificate; or
         have legal parental responsibilities for a child aged under 5 (or a child aged under 18 if disabled).

The purpose of parental leave is to care for your child. This means looking after their welfare and could include
making arrangements for the good of your child.

Caring for a child does not necessarily mean being with the child 24 hours a day. Parental leave might be taken
simply to enable you to spend more time with your young child. Examples of the way parental leave might be
used include:

         spending more time with your child in their early years
         accompanying your child during a stay in hospital
         looking at new schools
         settling your child into new childcare arrangements
         enabling your family to spend more time together, for example, taking your child to stay with
          grandparents.

You can take parental leave immediately after your maternity, paternity or adoption leave providing you give the
correct notice.

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What are the provisions of Parental Leave?

         Each employee is entitled to a total of 13 weeks’ unpaid leave for each child until the child reaches 5
          years of age, or in the case of a child placed for adoption, within 5 years of placement or the child’s 18th
          birthday, whichever is earlier.

         Employees who are the parents of a disabled child may take up to 18 weeks’ unpaid parental leave up to
          the child’s 18th birthday.

         Both parents have the right to parental leave. If you are separated and you don’t live with the children
          you have the right to parental leave if you keep formal parental responsibility for the children.


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      Parental leave is an individual right and you cannot transfer the leave between parents, for example, the
       father cannot decide to take only 10 weeks and the mother 16 weeks.

      Parental leave may be taken in blocks of a week, unless it is taken to care for a disabled child, when it
       can be taken in days. The employee can take no more than four weeks’ parental leave in any year. Part
       of a week counts as a full week in calculating parental leave taken for that year. For example, if a full-time
       employee takes three days’ parental leave and then returns to work, one week is deducted from the 13
       week entitlement.

      In the case of multiple births, there is an entitlement for Parental Leave for each child and the leave can
       be taken consecutively (with the agreement of the Company).

      Maternity Leave and Parental Leave can be taken consecutively by agreement with the Company.

      Existing social insurance rights will be protected by the award of credited contributions during periods of
       leave of one full week or longer in duration.

      Individuals also have a right to limited time off for family emergencies caused by accident or illness. This
       is referred to as force majeure leave and is dealt with separately in this Handbook.

      No more than 4 weeks’ leave can be taken in respect of any individual child during a particular year.


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Notice of Intention to take Parental Leave:

      Notice must be given, in writing, when an individual is taking Parental Leave. In order that the Company
       can make alternative arrangements for the performance of an individual’s duties, notice specifying the
       dates on which the period of leave is to begin and end is required at least 21 days before the date on
       which the leave is to begin.

      Where the employee is the father of the child, and the leave is to begin on the date that the child is born,
       the notice should specify the expected date of child birth and the duration of the periods of leave; and be
       given to the Company at least 21 days before the beginning of the expected week of childbirth.

      Where the leave is to be taken when a child is placed for adoption with the employee and the leave is to
       begin on the date of placement, the notice should specify the week in which the placement is expected to
       occur and the duration of the leave; and be given to the Company at least 21 days before the beginning
       of that week or if that is not reasonably practicable, as soon as it is reasonably practicable.

      Once the arrangements for the Parental Leave are agreed, they are outlined in a confirmation document
       which is signed by both the individual and the Company. This document will be prepared before the
       leave is due to begin.
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Postponing Parental Leave on the basis of Business Needs:

      An application for Parental Leave can be refused where the Company has sufficient grounds for believing
       that the operation of the business would be unduly disrupted if the employee took leave during the period
       identified in his/her notice.

      Parental Leave cannot be postponed in the case of a father wishing to take parental leave at the birth of
       his child nor when a child is being placed for adoption and the parental leave is to be taken at the date of
       placement.


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      Parental Leave can only be postponed to an agreed date or to a suitable future period for up to, but no
       more than, six months.

      The Company will give the employee notice in writing of the postponement which states the reason for it
       and specifies the dates on which the period of leave will begin and end. This notice will be given to the
       employee not more than 7 days after the employee’s notice was given to the Company.

      Parental leave may be postponed more than once in respect of a particular child as long as the above
       requirements are met. If, solely as a result of postponement, the child concerned reaches the age limit
       before the end of the leave, the employee retains the entitlement to take the parental leave.
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Refusing / Terminating Parental Leave

      An application for Parental Leave can be refused where the Company has sufficient grounds for believing
       that the employee is not entitled to Parental Leave. Before refusing to grant the leave, however, the
       Company must notify the individual, in writing, of its intention to do so, and invite the individual to make
       representations on the matter within 7 days. The Company is obliged to consider the individual’s
       submission before deciding whether to refuse the leave. The reason for refusal must be specified in
       writing.

      It is a condition of Parental Leave that it is used to take care of the child concerned. If the Company is
       satisfied that the Parental Leave is not being so used, the Parental Leave can be terminated. The
       individual must be notified, in writing, of such termination. 7 days must be allowed between the giving of
       the notice of termination and the date of termination of the Parental Leave.

      Disciplinary action will be taken against any person who abuses this Parental Leave Policy. Examples of
       abuse include taking Parental Leave for purposes other than taking care of the child concerned, or
       engaging in work for another company or person while on Parental Leave.
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Employees’ Rights regarding Parental Leave

      Individuals on Parental Leave will be treated as if they had not been absent so that all their employment
       rights, except the right to remuneration and pension benefits, will be unaffected during the leave. The
       absence, therefore, will count as reckonable service for the purpose of annual leave, increments,
       seniority, etc.

      Individuals retain an entitlement to any public holidays falling during a period of Parental Leave. A
       corresponding number of days in lieu of public holidays will be added to the end of the period of leave.
       (Where an individual is normally paid for public holidays, payment for days in lieu will be made in the next
       pay period on return from Parental Leave).
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Disputes and Appeals:

Disputes about entitlements to Parental Leave should be referred in the first instance to your line manager in
accordance with the Company’s Grievance Procedure. If the dispute remains unresolved through the Grievance
Procedure, it may be referred to an Industrial Tribunal. The Industrial Tribunal is empowered to hear the parties
to the dispute and to receive any relevant evidence tendered.

Notice to an Industrial Tribunal in relation to a dispute must be given no later than three months after the
occurrence of the dispute. The amount of compensation shall be such as the Tribunal considers just and
equitable in all the circumstances having regard to the employer’s behaviour and any loss sustained by the
employee which is attributable to the matters complained of.




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Administration of Parental Leave

The administration of Parental Leave will be carried out by the Operations Manager.
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Special Note: Parental Leave for children receiving a disability living allowance

   1. A parent of a child who is entitled to a disability living allowance is entitled to take up to 18 weeks’
      parental leave in blocks or multiples of one day.

   2. In the case of a child with a disability, the parent may take leave up until the child’s 18th birthday.

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Adoptive Parents

Rights to adoption and paternity leave and pay entitle eligible employees to take paid leave when a child is newly
placed for adoption. Adoptive leave and pay are available to:

      Individuals who adopt
      One member of a married couple where a couple adopts jointly (the couple may choose which partner
       takes adoption leave)

The partner of an individual who adopts, or the other member of a couple who are adopting jointly, may be
entitled to paternity leave and pay.
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Eligibility

Both paid adoption leave and paid paternity leave will be available to employees where an approved agency
notifies the adopter of a match with a child.

To qualify for adoption leave an employee must –

      be *newly matched with a child for adoption by an approved agency
      have worked continuously for the company for 26 weeks leading into the week in which they are notified
       of being matched with a child for adoption

*Adoption leave and pay is not available in circumstances where a child is not newly matched for adoption, for
example when a step-parent is adopting a partner’s children.
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Length of adoption leave

Adopters will be entitled to up to 26 weeks’ ordinary adoption leave followed immediately by up to 26 weeks’
additional adoption leave – a total of up to 52 weeks’ leave.

They can choose to start their leave –

      from the date of the child’s placement (whether this is earlier or later than expected), or
      from a fixed date which can be up to 14 days before the expected date of placement but no later than the
       date of placement.

Leave can start on any day of the week.

Only one period of leave will be available irrespective of whether more than one child is placed for adoption as
part of the same arrangement.
2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                             Page 35 of 138
If the child’s placement ends during the adoption leave period, the adopter will be able to continue adoption
leave for up to 8 weeks after the end of the placement.


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Statutory Adoption Pay

During their adoption leave, most adopters will be entitled to Statutory Adoption Pay (SAP) from the Company.

Statutory Adoption Pay will be paid by employers for up to 39 weeks. The rate of Statutory Adoption Pay will be
the same as the standard rate of Statutory Maternity Pay – (currently £128.73 per week (from April 2011) or 90%
of average weekly earnings, whichever is less).

Adopters who have average weekly earnings below the Lower Earnings Limit for National Insurance
Contributions (currently £102 a week) will not qualify for SAP. Such employees should contact their local Social
Security Office or Inland Revenue for further information on additional financial support which might be available
to them.
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Notice of intention to take adoption leave

Adopters will be required to inform the Operations Manager of their intention to take adoption leave within 7 days
of being notified by their adoption agency that they have been matched with a child for adoption, unless this is
not reasonably practicable in which case he/she should notify the Company as soon as possible. They will need
to tell the Company

      when the child is expected to be placed with them; and
      when they want their adoption leave to start

Adopters will be able to change their mind about the date on which they want their leave to start providing they
tell the company at least 28 days in advance (unless this is not reasonably practicable). They will have to tell the
company the date they expect any payments of SAP to start at least 28 days in advance, unless this is not
reasonably practicable.

The company will within 28 days write to the employee, setting out the date on which they expect the employee
to return to work if the full entitlement to adoption leave is taken.

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Matching Certificate

Employees will have to give the company documentary evidence – a ‘matching certificate’ – from their adoption
agency as evidence of their entitlement to SAP and leave. Employers can also ask for this certificate as proof of
entitlement to adoption leave. Employees should ask their adoption agency for a matching certificate which will
include basic evidence on matching and expected placement dates.

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Contractual benefits

Employees are entitled to the benefit of their normal terms and conditions of employment, except for terms
relating to wages or salary, throughout their adoption leave period.

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Return to work after adoption leave

Employees who take ordinary adoption leave (26 weeks) have the right to return to the same job. Employees
who take additional adoption leave have the right to return the same job, unless this is not reasonably
practicable, in which case they have the right to be offered a suitable alternative job under terms and conditions
which are no less favourable.


2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                           Page 36 of 138
Adopters who intend to return to work at the end of their full adoption leave entitlement (52 weeks) will not have
to give any further notification to the company.

Adopters who want to return to work before the end of their adoption leave period must give the company 28
days’ notice of the date they intend to return.

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Paternity Leave

Policy statement

Adelaide Insurance Services recognises the importance of supporting employees who wish to take a period of
ordinary or additional paternity leave. The aim of this policy is to ensure employees are aware of their statutory
entitlements and to ensure fair and equitable treatment in line with current legislation.

The right to take ordinary and additional paternity leave is in addition to the right of eligible employees, both
mothers and fathers, to take parental leave to care for their children.

   Ordinary paternity leave

Subject to the relevant eligibility conditions and notification requirements, employees are entitled to take up to
two weeks’ ordinary paternity leave (OPL) following the birth of a child or following the placement of a child for
adoption (from within the UK or from overseas). OPL may only be taken in ‘blocks’ of one or two weeks. Odd
days’ leave are not permitted.

   Additional paternity leave

Where a child is born or adopted on or after 3 April 2011, eligible employees may also take up to 26 weeks’
additional paternity leave within the first year of the child’s life, provided that the child’s mother or the other
adopter has returned to work before the end of their maternity or adoption leave.

   Statutory paternity pay

Employees who are eligible for ordinary paternity leave will also qualify for ordinary paternity pay (OPP) during
their leave period, provided their average weekly earnings are above the lower earnings limit for national
insurance. OPP is paid at a standard rate, which is determined by Government.

Employees who qualify for additional paternity leave (APL) may also qualify for additional paternity pay (APP)
during this period, provided the mother of the child or other adopter has returned to work with at least two
weeks of their statutory maternity pay, maternity allowance or statutory adoption pay unexpired. An employee
on APL may be entitled to receive the unused balance of their partner’s 39 weeks’ statutory payments as
APP. APP is paid at the same rate as ordinary paternity pay.


   Rights during and after a period of statutory paternity leave

During ordinary and additional paternity leave, all contractual terms and conditions of employment will be
preserved, with the exception of remuneration, which will be replaced by ordinary or additional paternity pay.

Following a period of ordinary paternity leave, employees are entitled to return to the same job.

Following a period of additional paternity leave, employees are entitled to return to the same job, on the same
terms and conditions as before, provided the leave was:

   an isolated period of leave; or
   the last of two or more consecutive periods of statutory leave (not including any period of additional
    maternity or adoption leave or a period of parental leave that lasts for more than four weeks).

2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                               Page 37 of 138
Where these conditions are not met, the employee is entitled to return to the same job or, if this is not
reasonably practicable, a suitable and appropriate alternative.

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Ordinary paternity leave for the birth of a child

   Eligibility

    To be eligible for ordinary paternity leave (OPL) following the birth of a child, you must:

    °   have or expect to have responsibility for the child’s upbringing;
    °   be the child’s biological father or the mother’s husband or partner, who is not the child’s biological father
        (this can include a female partner in a same sex relationship); and
    °   have 26 weeks’ continuous service with the company by 15th week before the expected week of
        childbirth.

   Notification

    If you wish to take OPL, you must notify the company by the 15th week before the baby is due, unless this is
    not reasonably practicable. Your notification must include:

    °   the date when the baby is due;
    °   whether you want to take one or two weeks’ OPL; and
    °   the date when you would like your OPL to start.

    You are advised to use the Ordinary paternity leave self certificate (birth) for this purpose. This can be
    found in the Appendices of this booklet.

    If you subsequently wish to change the start date of your leave, you must give 28 days' written notice of the
    revised start date, unless this is not reasonably practicable.

    You are advised to use the Ordinary paternity leave – change to start date form for this purpose. This
    can be found in the Appendices of this booklet.

       Timing

    OPL can only be taken in ‘blocks’ of one or two weeks. You will not be permitted to take odd days’ leave.
    Your OPL can begin:

    °   from the date the baby is born; or
    °   from a chosen number of days or weeks after the baby’s date of birth; or
    °   from a chosen date.

    You must take your OPL within 56 days of either the baby’s birth or the first day of the expected week of
    childbirth. If the baby is born early, you must take your OPL at a time between the baby’s actual birth date
    and 56 days after the baby was due.

    You can only take one period of OPL, even if more than one child is born.
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Ordinary paternity leave for the adoption of a child within the UK

   Eligibility

    As you may be aware, subject to the relevant eligibility conditions and notification requirements, an employee
    who adopts a child may be entitled to statutory adoption leave and pay (see section ‘Adoptive Parents’). The
    partner of a person who adopts a child, or the other member of a couple who are adopting jointly, may take
    paid ordinary paternity leave (OPL), provided that he/she is eligible. The couple may choose which of them

2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                             Page 38 of 138
    takes adoption leave and which takes OPL. To be eligible for OPL for the adoption of a child within the UK,
    you must:

    °   have or expect to have responsibility for the child’s upbringing;
    °   be the adopter’s spouse or partner (male or female); and
    °   have 26 weeks’ continuous service with the company by the week in which the adopter is notified of
        being matched with a child.

   Notification

    If you wish to take ordinary paternity leave (OPL), you must notify the company within seven days of the
    adopter being informed of a match with a child, unless this is not reasonably practicable. Your notification
    must include:

    °   the date when the child is expected to be placed;
    °   whether you want to take one or two weeks’ OPL; and
    °   the date when you would like your OPL to start.

    You are advised to use the Ordinary paternity leave self certificate (UK adoption) for this purpose. This
    can be found in the Appendices of this booklet.

    If you subsequently wish to change the start date of your leave, you must give 28 days' written notice of the
    revised start date, unless this is not reasonably practicable.

    You are advised to use the Ordinary paternity leave – change to start date form for this purpose. This
    can be found in the Appendices of this booklet.

   Timing

    Ordinary paternity leave (OPL) can only be taken in blocks of one or two weeks. You will not be permitted to
    take odd days’ leave. Your OPL can begin:

    °   from the date of the child’s placement; or
    °   from a chosen number of days or weeks after the child’s placement; or
    °   from a chosen date.

    You must take your OPL within 56 days of the child’s placement.

    You can only take one period of OPL, even if more than one child is placed at the same time.

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Ordinary paternity leave for the adoption of a child from overseas

   Eligibility

    As you may be aware, subject to the relevant eligibility conditions and notification requirements, an employee
    who adopts a child may be entitled to statutory adoption leave and pay (See section ‘Adoptive Parents’). The
    partner of a person who adopts a child, or the other member of a couple who are adopting jointly, may take
    paid ordinary paternity leave (OPL), provided that he/she is eligible. The couple may choose which of them
    takes adoption leave and which takes OPL. To be eligible for OPL for the adoption of a child from overseas
    you must:

    °   have or expect to have responsibility for the child’s upbringing;
    °   be the adopter’s spouse or partner (male or female); and
    °   have 26 weeks’ continuous service ending with the week in which the adopter receives official
        notification from the relevant authority or, if the adopter received official notification before you joined the
        company, 26 weeks’ continuous service with the company.


2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                               Page 39 of 138
   Notification

    If you wish to take ordinary paternity leave (OPL), within 28 days of the adopter receiving official notification
    (or, if the adopter received official notification before you joined the company, within 28 days of the date on
    which you complete 26 weeks’ continuous service with the company), you must notify the company of:

    °   the date when the adopter received official notification; and
    °   the date when the child is expected to enter the country.

    You must give the company 28 days’ notice of:

    °   when you want you would like your OPL to start; and
    °   whether you want to take one or two weeks’ paternity leave.

    You must also inform the company of the date when the child entered the country, no later then 28 days after
    the entry date.

    You are advised to use the Ordinary paternity leave self certificate (overseas adoption) for this purpose.
    This form is in three parts and can be found in the Appendices of this booklet.

   Timing

    Ordinary paternity leave (OPL) can only be taken in blocks of one or two weeks. You will not be permitted to
    take odd days’ leave. Your OPL can begin at any time within 56 days of the child’s entry into the country.

    You can only take one period of paternity leave, even if more than one child is placed at the same time.


Statutory paternity pay during ordinary paternity leave

Provided your weekly earnings are above the lower earnings limit for national insurance, ordinary paternity pay
(OPP) will be paid for either one or two weeks, depending on the amount of ordinary paternity leave you have
chosen to take.

OPP is paid at a standard rate. Currently (as at 6 April 2011) this is £128.73 per week, or 90% of your average
weekly earnings if this is less than £128.73.

If your average earnings are below the national insurance threshold and you are therefore ineligible for OPP, you
may be able to claim social security benefits while you are on paternity leave.

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Rights during ordinary paternity leave

During ordinary paternity leave (OPL), all of your contractual terms and conditions, with the exception of
remuneration, are preserved. This means that non-pay company benefits which apply to you, such as life cover,
private health insurance, will continue during your OPL. However, your salary/wages will be replaced by SPP, if
you are eligible to receive it.

If you are a member of the Company’s pension scheme, contributions will continue while you are receiving
statutory paternity pay. The employer contribution will continue at the usual percentage of your normal basic
monthly salary, while your contribution will be calculated as a percentage of your actual monthly pay.
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Returning to work after ordinary paternity leave

When you return to work after your ordinary paternity leave (OPL), you will return to the same job.

If, for any reason, you are unable to return to work at the end of your OPL, you should contact the company
immediately, as you would for any other absence from work.
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2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                             Page 40 of 138
Additional paternity leave for the birth of a child

     Eligibility

      Additional paternity leave (APL) is only available where a child is born on or after 3 April 2011.

      Entitlement to APL is subject to a number of conditions, some of which apply to you as the employee who
      wishes to take the leave and some of which apply to the mother of the child.

      The mother of the child must:

             be entitled to one or more of: statutory maternity leave; maternity pay; maternity allowance; and
             have returned to work.

      As the employee who wishes to take APL, you must fulfil the eligibility conditions for ordinary paternity
      leave and:

             remain in continuous employment until the week before the first week of your leave; and
             provide the company with: leave notice; an employee declaration; a mother’s declaration and, if
              required, further evidence or information in support of your application.


     Notification

You are required to notify the company at least eight weeks before the date when you want your APL to start.
The notification must include:

             a written leave notice, which specifies: the expected week of childbirth; the actual date on which the
              baby was born; the date on which you want your leave to start and the date on which you want it to
              end; and

             a signed employee declaration, which states that you satisfy the eligibility conditions for APL and that
              the purpose of the leave is to allow you to care for the child.

    You must also provide the company with a declaration signed by the mother of the child that states:

               her name and address;

               her national insurance number;

               the date when she intends to return to work;

               that you satisfy the eligibility conditions set out in your declaration;

               that, to her knowledge, you are the only person taking leave in respect of her baby; and

               that she consents to the company processing the information contained in her declaration.

    If you are eligible for additional paternity pay, the notification must also include details of your additional
    paternity pay period (see below) and the mother’s statutory maternity pay or maternity allowance period.

    You are advised to use the Additional paternity leave employee’s notice and declaration (birth) and the
    Additional paternity leave mother’s declaration (birth) for this purpose. These forms satisfy the notification
    requirements for additional paternity leave and pay and can be found in the Appendices section of this booklet.

    Within 28 days of receiving your notification, the company may ask you to provide a copy of the child’s birth
    certificate and the name and address of the mother’s employer, or the mother’s business address if she is
2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                                  Page 41 of 138
    self-employed. You must supply the company with this information and documentation within 28 days of the
    company’s request.

    If you change your mind about when you want to begin your APL, you must notify the company at least six
    weeks in advance of the original start date or the new start date (whichever is the earlier). If this is not
    possible, you must notify the company as soon as is reasonably practicable.

    You are advised to use an Additional paternity leave change of start date form for this purpose. This can
    be found in the Appendices section of this booklet.

    Within 28 days of receiving your leave notification or a subsequent notice of a change of dates, the
    company will write to you confirming the dates on which your additional paternity leave will start and end.

     Timing

      For you to qualify for additional paternity leave (APL), the mother of the child has to have returned to work
      before using their full entitlement to statutory maternity leave.

      The minimum period of APL is two consecutive weeks and the maximum period is 26 weeks. APL must
      be taken in a single block of complete, consecutive weeks.

      APL cannot begin any earlier than 20 weeks after the date on which the child was born and must end no
      later than 12 months after this date.

      You are only entitled to one period of APL for each pregnancy, even if more than one child is born at the
      same time.

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Additional paternity leave for the adoption of a child within the UK

     Eligibility

      Additional paternity leave (APL) is only available where a child is adopted on or after 3 April 2011.

      Entitlement to APL is subject to a number of conditions, some of which apply to you as the employee who
      wishes to take the leave and some of which apply to the other adopter of the child.

      The other adopter of the child must:

         be entitled to one or both of: statutory adoption leave; statutory adoption pay; and
         have returned to work.

      As the employee who wishes to take additional paternity leave, you must fulfil the eligibility conditions for
      ordinary paternity leave and:

         remain in continuous employment until the week before the first week of your leave; and
         provide the company with: leave notice; an employee declaration; an adopter’s declaration and, if
          required, further evidence or information in support of your application.


     Notification

You are required to notify the company at least eight weeks before the date when you want your additional
paternity leave to start. The notification must include:




2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                               Page 42 of 138
         a written leave notice, which specifies: the date on which you were notified by the adoption agency of
          having been matched with a child; the date on which the child was actually placed with you; the date
          on which you want your leave to start and the date on which you want it to end; and

         a signed employee declaration, which states that you satisfy the eligibility conditions for additional
          paternity leave, have been matched with a child and that the purpose of the leave is to allow you to
          care for the child.

      You must also provide the company with a declaration signed by the other adopter of the child that states:

         their name and address;

         their national insurance number;

         the date when they intend to return to work;

         that you satisfy the eligibility conditions set out in your declaration; and

         that they consent to the company processing the information contained in their declaration.

    If you are eligible for additional paternity pay, the notification must also include details of your additional
    paternity pay period (see below) and the other adopter’s statutory adoption pay period.

    You are advised to use the Additional paternity leave employee’s notice and declaration (UK adoption)
    and the Additional paternity leave adopter’s declaration (UK adoption) for this purpose. These forms
    satisfy the notification requirements for additional paternity leave and pay and can be found in the Appendices
    section of this handbook.

    Within 28 days of receiving your notification, the company may ask you to provide:

         the name and address of the adoption agency;
         the date when you were notified of a match with the child;
         the date when the adoption agency expects to place the child with you and the other adopter; and/or
         the name and address of the other adopter’s employer, or their business address if they are self-
          employed.

    You must supply the company with this information and documentation within 28 days of the company’s
    request.

    If you change your mind about when you want to begin your additional paternity leave, you must notify the
    company at least six weeks in advance of the original start date or the new start date (whichever is the
    earlier). If this is not possible, you must notify the company as soon as is reasonably practicable.

    You are advised to use an Additional paternity leave change of start date form for this purpose. This can
    be found in the Appendices of this booklet.

    Within 28 days of receiving your leave notification or a subsequent notice of a change of dates, the
    company will write to you confirming the dates on which your additional paternity leave will start and end.

     Timing

      For you to qualify for additional paternity leave (APL), the other adopter of the child has to have returned
      to work before using their full entitlement to statutory adoption leave.

      The minimum period of APL is two consecutive weeks and the maximum period is 26 weeks. APL must
      be taken in a single block of complete, consecutive weeks.


2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                                  Page 43 of 138
    APL cannot begin any earlier than 20 weeks after the date on which the child was placed for adoption and
    must end no later than 12 months after this date.

    You are only entitled to one period of APL for each adoption, even if more than one child is adopted at the
    same time.

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Additional paternity leave for the adoption of a child from overseas

   Eligibility

    Additional paternity leave (APL) is only available where a child is adopted on or after 3 April 2011.

    Entitlement to APL is subject to a number of conditions, some of which apply to you as the employee who
    wishes to take the leave and some of which apply to the other adopter of the child.

    The other adopter of the child must:

       be entitled to one or both of: statutory adoption leave; statutory adoption pay; and
       have returned to work.

    As the employee who wishes to take APL, you must fulfil the eligibility conditions for ordinary paternity
    leave and:

       remain in continuous employment until the week before the first week of your leave; and
       provide the company with: leave notice; an employee declaration; an adopter’s declaration and, if
        required, further evidence or information in support of your application.
   Notification

You are required to notify the company at least eight weeks before the date when you want your additional
paternity leave (APL) to start. The notification must include:

       a written leave notice, which specifies: the date on which you were notified by the relevant domestic
        authority; the date when the child entered the country; the date on which you want your APL to start
        and the date on which you want it to end;

       a signed employee declaration, which states that you satisfy the eligibility conditions for APL, that the
        purpose of the leave is to allow you to care for the child and that you will have responsibility for the
        child’s upbringing.

    You must also provide the company with a declaration signed by the other adopter of the child that states:

       their name and address;

       their national insurance number;

       the date when they intend to return to work;

       that you satisfy the eligibility conditions set out in your declaration; and

       that they consent to the company processing the information contained in their declaration.




2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                            Page 44 of 138
    If you are eligible for additional paternity pay, the notification must also include details of your additional
    paternity pay period (see below) and the other adopter’s statutory adoption pay period.

    You are advised to use the Additional paternity leave employee’s notice and declaration (overseas
    adoption) and the Additional paternity leave adopter’s declaration (overseas adoption) for this purpose.
    These forms satisfy the notification requirements for additional paternity leave and pay and can be found in the
    Appendices of this booklet.

    Within 28 days of receiving your notification, the company may ask you to provide:

            a copy of the official notification;
            evidence of the date when the child entered the country; and/or
            the name and address of the adopter’s employer, or their business address if they are self-employed.

    You must supply the company with this information and documentation within 28 days of the company’s
    request.

    If you change your mind about when you want to begin your APL, you must notify the company at least six
    weeks in advance of the original start date or the new start date (whichever is the earlier). If this is not
    possible, you must notify the company as soon as is reasonably practicable.

    You are advised to use an Additional paternity leave change of start date form for this purpose. This can
    be found in the Appendices of this booklet.

    Within 28 days of receiving your leave notification or a subsequent notice of a change of dates, the
    company will write to you confirming the dates on which your APL will start and end.

       Timing

        For you to qualify for additional paternity leave (APL), the other adopter of the child has to have returned
        to work before using their full entitlement to statutory adoption leave.

        The minimum period of APL is two consecutive weeks and the maximum period is 26 weeks. APL must
        be taken in a single block of complete, consecutive weeks.

        APL cannot begin any earlier than 20 weeks after the date on which the child entered the country and
        must end no later than 12 months after this date.

        You are only entitled to one period of APL for each adoption, even if more than one child is adopted at the
        same time.

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Additional paternity pay

If you qualify for additional paternity leave (APL), you may also qualify for additional paternity pay (APP)
during this period, provided:

           you remain in continuous employment until the week before your APP period begins;
           you comply with the notification requirements (see above) ;
           your average weekly earnings are above the lower earnings limit for national insurance purposes;
           the mother or other adopter of the child is entitled to statutory maternity pay, maternity allowance or
            statutory adoption pay and has returned to work with at least two weeks of their entitlement unexpired.

Where this is the case, you will be entitled to receive the unused balance of your partner’s 39 weeks’ statutory
maternity pay, maternity allowance or statutory adoption pay, while you are on APL. For example, if the
mother of your child has received 27 weeks’ statutory maternity pay, you would be entitled to up to 12 weeks’
2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                                  Page 45 of 138
additional paternity pay (the balance of the 39 week statutory maternity pay period), while you were on APL.
However, if the mother has received 27 weeks’ statutory maternity pay and you then opt to take 18 weeks’
additional paternity leave, the last six weeks of your leave would be unpaid.

APP is paid at the same rate as ordinary paternity pay. Currently this is £128.73 per week, or 90% of your
average weekly earnings if this is less than £128.73.

If your average earnings are below the national insurance threshold and you are therefore ineligible for APP, you
may be able to claim social security benefits while you are on APL.

You may not normally undertake any paid work whilst in receipt of APP. However, you are allowed to work for up
to ten “keeping in touch” days without losing your right to APP or bringing your period of APL to an end. Work for
this purpose includes training or briefing sessions designed to help you to keep up to date with developments
during your absence. Any such “keeping in touch” days will be by agreement between you and the Company.
You are not obliged to work on any “keeping in touch” days if you do not wish to do so and the Company is not
obliged to offer you any such days.

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Rights during additional paternity leave

During additional paternity leave (APL), all of your contractual terms and conditions, with the exception of
remuneration, are preserved. This means that non-pay company benefits which apply to you, such as life cover,
private health insurance, will continue during the whole of your APL. However, your salary/wages will be
replaced by additional paternity pay, if you are eligible to receive it.

If you are a member of the Company’s pension scheme, contributions will continue while you are receiving
statutory paternity pay. The employer contribution will continue at the usual percentage of your normal basic
monthly salary, while your contribution will be calculated as a percentage of your actual monthly pay.

The Company is entitled make reasonable contact with you during your APL.
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Returning to work after additional paternity leave

You have no need to notify the company if you intend to return to work on the due day at the end of your
additional paternity leave (APL). However, if you wish to return early, before the end of your APL, you must give
at least six weeks' notice in writing to the Company of the date on which you intend to return. If you fail to do this,
the company may postpone your return. You are advised to use the Notification of early return from
additional paternity leave form for this purpose. This can be found in the Appendices of this booklet.

You should be aware that if you return to work before the end of this six weeks’ notice period, the Company
will be under no obligation to pay you until the six weeks have elapsed.

On your return from APL, you will be entitled to come back to the same job, on the same terms and conditions
as before, provided the leave was:

   an isolated period of leave; or
   the last of two or more consecutive periods of statutory leave (not including any period of additional
    maternity or adoption leave or a period of parental leave that lasts for more than four weeks).

Where these conditions are not met, you will be entitled to return to the same job or, if this is not reasonably
practicable, a suitable and appropriate alternative.

If, for any reason, you are unable to return to work by the end of your APL, you should contact the company
immediately. Failure to return to work on the due date may be treated as an unauthorised absence. If you are
unable to return to work because of illness, you must comply with the company’s normal procedures for notifying
sickness absence and submitting medical certificates.

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If you decide during APL that you do not wish to return to work, you should give written notice of your resignation
to the Company as soon as possible and in accordance with the terms of your contract of employment.

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Flexible Working

Anyone can ask their employer for flexible working arrangements, but the law provides some employees with the
statutory right to request a flexible working patterns and employers will have a duty to consider these requests
seriously.

It will not provide an automatic right to work flexibly as there will be circumstances when the company is unable
to accommodate the employee’s desired work pattern.

If the new pattern is accepted this will be a permanent change in the employee’s terms and conditions with no
right in law to revert back to the previous working pattern.
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Who can ask for flexible working?

You must:

      be an employee, but not an agency worker;
      have worked for the company continuously for a period of not less than 26 weeks at the date the
       application is made;
      have not made another application to work flexibly under the right during the past 12 months.

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You will then have the statutory right to ask if you:

      have or expect to have parental responsibility of a child aged under 17,
      have or expect to have parental responsibility of a disabled child under 18 who receives Disability Living
       Allowance (DLA)
      are the parent/guardian/special guardian/foster parent/private foster carer or as the holder of a residence
       order or the spouse, partner or civil partner of one of these and are applying to care for the child
      are a carer who cares, or expects to be caring, for an adult who is a spouse, partner, civil partner or
       relative; or who although not related to you, lives at the same address as you.

       “Partner” means a person (whether of a different sex or the same sex) who lives with the child and the
       mother, father, adopter, guardian or foster parent in an enduring family relationship but is not a relative.

       “Relative” means parent, grandparent, sister, brother, aunt or uncle.

       These relationships can be full blood or half blood or in the case of an adopted person such as those
       relationships would exist but for the adoption, and include the relationship of a child with his adoptive, or
       former adoptive, parents, but do not include any other adoptive relationships.

If the employee has made an application under the right he/she may not make further application to the company
before the end of the period of twelve months beginning with the date on which the previous application was
made.

The purpose of the request must be to enable the employee to care for the child/person.
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Scope of a request

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Eligible employees will be able to request changes to:

      the hours he/she is required to work
      the time when he/she is required to work
      where, as between his/her home and place of business of his/her the company, he/she is required to
       work, or
      such other aspect of his/her terms and conditions of employment as the Department for Employment &
       Learning may specify by regulations.

This covers working patterns such as annualised hours, compressed hours, flexitime, home working, job-
sharing, self-rostering, shift working, staggered hours and term time working.
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Procedure

If you have the statutory right to apply, then there is a process you must follow. You should bear in mind that,
under the statutory procedure, the process of making a request and your employer considering it can take up to
14 weeks. So if you are thinking about changing your work pattern, you should speak to your employer as early
as possible.

You should also be aware that, if your employer agrees to your request, then it may result in a permanent
change to your contract of employment. If you request a flexible pattern that will result in you working fewer
hours, your pay will reduce too. If you do not have the right to request flexible working then the statutory process
will still be helpful to you and you should consider speaking to your employer as early as possible.

The application under the legislation must:

      be in writing (whether on paper form or email form)
      state that it is such an application
      specify the change applied for and the date on which it is proposed the change should become effective
      explain what effect, if any, the employee thinks making the change applied for would have on the
       company and how, in his/her opinion, any such effect might be dealt with, and
      explain how the employee meets, in respect of the child concerned, the conditions as to the relationship
       with a relevant child set out above
      state whether a previous application has been made to the employer and, if so, when
      be dated

Applications for flexible working should be forwarded to the Operations Manager
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Procedure following application

Where the company consents to the variation as proposed by the employee

If the company agrees to the contract variation proposed by the employee, the Operations Manager will notify
the employee in writing (whether on paper or email) within 28 days after the date on which the application is
made of:
      the contract variation agreed to
      the date on which the variation is to take effect

Where the employer is unsure, contemplating refusal or an amended proposal

If the company is unsure, contemplating refusal or an amended proposal the Operations Manager will hold a
meeting to discuss the application with the employee within 28 days after the date on which the application is
made.

The meeting will give the opportunity to explore the desired work pattern in depth and to discuss how best it
might be accommodated. It will also provide an opportunity to consider other alternative working patterns should
there be problems in accommodating the desired work pattern outlined in the employee’s application.

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The time and place of the meeting shall be convenient to the company and the employee.

The employee has the right to be accompanied to this meeting by a worker employed by the company (the right
to be accompanied does not extend to a trade union representative). The companion may address the meeting
and confer with the employee but can not answer questions on behalf of the employee.

If the chosen companion is not available at the time proposed for the meeting by the company and the employee
proposes an alternative time the company will postpone the meeting to the time proposed by the employee. The
alternative time must be convenient to the company, employee and companion and fall before the end of the
period of seven days beginning with the first day after the day proposed by the company.

The company will permit a worker time off during working hours for the purpose of accompanying an employee.

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Calculation of the start of the period of 28 days

Unless the contrary is proved, an application is taken as having been made on the day the application is
received. The day on which it is received is:

      where an application is sent by post the day on which the application would be delivered in the ordinary
       course of post.
      where an application is transmitted by electronic communication, the day on which it is transmitted.

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Notification of the decision

Within fourteen days after the date of the meeting the company will give the employee notice of his/her decision
on the application.

The notice shall:
    be in writing (whether on paper or electronic communication)
      where the decision is to agree to the contract variation:
          o specify the variation agreed to
          o the date from which the contract variation is to take effect
      where the decision is to refuse the contract variation
          o state which of the statutory grounds for refusal are considered to apply
          o contain sufficient explanation as to why those grounds for refusal apply on relation to the
              application
          o set out the appeal procedure
      be dated

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Appeals

Employee’s notice of appeal

An employee is entitled to appeal against the company’s decision by giving notice within fourteen days after the
date on which notice of the decision is given. The notice shall:

      be in writing (whether on paper or electronic communication)
      set out the grounds of appeal
      be dated

An application should be forwarded to the Operations Manager. Appeals will usually be heard by the company
Director.


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Company’s duties following receipt of appeal notice

If within fourteen days after the appeal notice is given the company:

      upholds the appeal
      notifies the employee in writing of his decision specifying (whether on paper or email):
           o the contract variation agreed to
           o the date from which the contract variation is to take effect

there is no need to hold an appeal hearing. However, if the appeal is not upheld the employer shall hold a
meeting with the employee to hear the appeal within fourteen days after the date on which notice is given by the
employee.

The same provisions apply in relation to the appeal meeting as the original meeting as regards the time and
place of the meeting and the employee’s right to be accompanied.

Notification of the appeal decision

The company will notify the employee of his/her decision on appeal within fourteen days after the date of the
meeting to discuss the appeal. The notice shall:

      be in writing (whether on paper or email)
      where the company upholds the appeal
           o specify the contract variation agreed to
           o the date from which the variation is to take effect
      where the company dismisses the appeal:
           o state the grounds for the decision
           o contain sufficient explanation as to why those grounds apply
      be dated
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Extension of the time limits

The company and employee may agree to an extension of any of the time limits set out above.

An agreement must:
    be recorded in writing by the company
    specify what time the extension relates to
    specify the date on which the extension is to end
    be dated and
    sent to the employee

This provision is intended to cover situations such as those where, at the meeting to discuss the employee’s
application, the company has indicated a willingness to consider a compromise flexible working arrangement but
needs further time to assess its feasibility and likely impact on the business.

Where the individual who would ordinarily consider an application for flexible working is absent from work on
annual leave or sick leave on the day on which the application is made the time limit for holding the meeting to
consider the application commences on the day the individual returns to work or 28 days after the application is
made, whichever is sooner.

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Withdrawal of application by an employee

The company shall treat an application as withdrawn where the employee has:
    notified to him/her whether orally or in writing that he/she is withdrawing the application
    without reasonable cause, failed to attend either the meeting to consider the application or the appeal
      hearing more than once, or
    without reasonable cause, refused to provide the company with information the company requires in
      order to assess whether the contract variation should be agreed to
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The company will confirm the withdrawal of the application to the employee in writing unless the employee has
provided him with written notice of the withdrawal.
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Grounds for refusal

The company will only refuse an application because he/she considers that one or more of the following grounds
applies:

      the burden of additional costs
      detrimental affect on ability to meet customer demand
      inability to re-organise work among existing staff
      inability to recruit additional staff
      detrimental impact on quality
      detrimental impact on performance
      insufficiency of work during the periods the employee proposes to work
      planned structural changes, and
      such other grounds as the Department for Employment may specify by regulations.

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Copies of the following forms can be found in the Appendices section of this Handbook.

Form FW (A) Flexible Working - Application Form

Form FW (B) Flexible Working - Application Acceptance Form

Form FW (C) Flexible Working - Application Rejection Form

Form FW (D) Flexible Working - Appeal Form

Form FW (E) Flexible Working - Appeal Reply Form

Form FW (F) Flexible Working - Extension of Time Limit

Form FW (G) Flexible Working - Notice of Withdrawal Form
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Time off for Dependants

The Company complies with the Employment Rights (Northern Ireland) Order 1996 as amended &
accompanying Regulations, which introduced the right to time off for the care of dependants. The Company will
provide a reasonable amount of time off, which is unpaid, and necessary for the employee:

      To provide assistance on the occasion when a dependant falls ill, gives birth or is injured or assaulted.
      To make arrangements for the provision of care for a dependant who is ill or injured.
      Because of the death of a dependant (please see the section in this Handbook on the Company’s
       Compassionate Leave arrangements).
      Because of the unexpected disruption or termination of arrangements for the care of a dependant.
      To deal with an incident which involves the child of the employee and which occurs unexpectedly in a
       period during which an educational establishment that the child attends is responsible for him/her.

You must tell your Manager the reason for your absence as soon as reasonably practicable and let him/her know
how long you expect to be absent.

A review will take place should the time off extend beyond 13 weeks.


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A dependant is defined as your partner, spouse, child, parent or a person who lives in your household as part of
your family. It does not include an employee, tenant, lodger or boarder.
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Force Majeure

Purpose
The purpose of Force Majeure Leave is to provide paid leave, in the event that a member of an employee’s
family (i.e. a child/adoptive child, spouse/partner, a person to whom they are in loco parentis, a brother/sister or
parent/grandparent) has suffered an illness or injury.


Eligibility
All Adelaide employees are eligible but:
     only when due to an unforeseen event the immediate presence of the employee is indispensable, at the
        place where the ill/injured person is located.

Policy

        Entitlement to force majeure leave is limited to 3 days in any 12 consecutive months or 5 days in any 36
         consecutive months.
        Absence for part of a day is counted as one full day of force majeure leave.

Notification Procedures
An employee who is required to take such leave must inform his/her direct line manager as soon as is
reasonably practicable with the reason for leave taken. Thereafter, an employee must complete the Force
Majeure notice document on his/her return to work. (A copy can be found in the Appendices section of this
handbook)

Abuse of Leave
Where the leave is not taken for the above reason, the employee may be subject to serious disciplinary action,
up to and including dismissal.
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Compassionate Leave

Compassionate leave with pay is granted at the discretion of the Company in special circumstances such as
death of a family member. Normally compassionate leave will be granted as follows:
Immediate family member (parent, spouse, child, brother, sister):            3 days
Close relative (grandparent, aunt, uncle, nephew, niece, parent-in-law):     1 day
Arrangements for compassionate leave must be agreed with your manager.
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Jury Service

If employees are requested to attend jury service or attend court as a witness, they should produce the
notification documentation from the court and advise their manager and the Personnel Department as soon as
possible of the dates.
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Salary is normally paid in full less the expenses reimbursed for loss of earnings by the court. The salary
deduction will be made when the employee is reimbursed with those expenses.

If employees report for jury service or court but are not required to serve on any particular day, they will be
expected to attend for work for the remainder of the day.
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Part 3                         Disciplinary and Grievance Procedures
                                                      “Try to see it my way
                                           do I have keep on talking till I can’t go on”

                                               We Can Work It Out - The Beatles


Disciplinary Procedure

Adelaide requires the highest standards of performance, conduct and commitment from staff. Where Adelaide
believes that a staff member falls short of its requirements, the Disciplinary procedures set out below will be
invoked. The purpose of the procedure is to acquaint staff members with the concerns of the Company and to
identify the steps necessary to rectify the situation. Adelaide will assist staff in achieving the required standards
wherever possible.

Purpose and scope
This procedure is designed to help and encourage all members of staff to achieve and maintain standards of
conduct, attendance and job performance. The procedure is referred to in the particulars of your employment
but in non-contractual.

Principles
      No disciplinary action will be taken against a member of staff until the case has been fully investigated.
       In some cases it may be necessary for an individual to be suspended on a precautionary basis until the
       investigation has been completed. Full pay will be maintained during the suspension period.

      At every stage in the procedure the member of staff will be advised of the nature of the complaint against
       him/her and will be given the opportunity to state his/her case before any decision is made.

      At all stages the member will have the right to be accompanied by a work colleague of their choice or a
       trade union official during the disciplinary interview.

      No member of staff will be dismissed for a first breach of discipline except in the case of gross
       misconduct when the penalty may be dismissal without notice or payment in lieu of notice.

      At all stages, a penalty may include a demotion from the member of staff’s current role (which would
       include reduction in salary and other benefits).

      A member of staff will have the right to appeal against any disciplinary penalty imposed.

      The procedure may be implemented at any stage if the member of staff’s alleged misconduct warrants
       such action.

      The procedure does not apply to employees during the probationary period.

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Procedure
Minor faults will be dealt with informally with individual members of staff being warned about faults in their
conduct or performance. Such preliminary warnings will not form part of the disciplinary procedure. It is
expected that at this stage maximum effort should be made to train, guide, or in any way help the individual to
bring their conduct or performance up to an acceptable standard. If the matter is more serious the following
procedure will be used. Following the findings of a hearing, the nature of the offence will determine the entry
stage to the disciplinary process (see diagram below).


Stage 1 – Verbal Warning
The Department Manager will verbally warn the staff member of the specific aspect of work attendance or
conduct which is below standard, stating clearly that it is the first warning, and will advise of the improvements
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which must be made. The warning will be noted and recorded on the staff member’s personnel file and they will
be advised of the right to appeal. Verbal warnings will remain noted for six months after which period the
warning is removed, provided the problem giving rise to the warning has not been repeated during the life of the
warning.


Stage 2 – Written Warning
If the offence is of a more serious nature, or if a further offence occurs, or if performance does not
improve within the timescale agreed at Stage 1, a written warning will be given to the member of staff by
the department manager following a meeting where he or she may be accompanied by a colleague. The written
warning will be recorded on the staff member’s personnel file, giving details of the complaint, the improvement
required and the timescale. It will warn that action under Stage 3 will be considered if there is no satisfactory
improvement and will advise of the right to appeal. Written warnings remain noted on the staff member’s record
for a period of twelve months, after which period, the warning is removed, provided the problem giving rise to the
warning has not been repeated during the life of the warning.


Stage 3 – Final written warning
If the offence is of a very serious nature, or if, despite the operation of Stages 1 and 2, the staff member
has still not improved to an acceptable level, he/she will receive a final written warning. The staff member
may be accompanied by a colleague. A senior executive together with the department manager will attend the
meeting at which notification of the final written warning is issued. The final written warning will be recorded on
the staff member’s personnel file and will notify him/her that if there is no immediate satisfactory and sustained
improvement, dismissal may result. They will be advised of the right of appeal. Final written warnings remain
noted on the staff member’s record for a period of twenty four months, after which period, the warning is
removed, provided the problem giving rise to the warning has not been repeated during the life of the warning.


Stage 4 – Dismissal
In cases of gross misconduct, you will normally be dismissed without notice or pay in lieu of notice. In
exceptional circumstances, of if there are any genuine mitigating circumstances alternative disciplinary action
may be taken.
Or
If, despite warnings in accordance with Stages 1, 2, & 3, the staff member has not improved sufficiently,
he/she will be dismissed. Only the appropriate senior manager can make the decision to dismiss. The
member of staff will be provided, as soon as reasonably practicable, with written reasons for the dismissal, the
date on which employment will terminate and the right of appeal.


Serious misconduct
This amounts to any serious breach, infringement or non-observance of the standards expected of members of
staff.
Examples include but are not limited to:

      Failure to carry out written or verbal instructions of a more senior member of staff
      Regular or persistent lateness
      Unacceptable performance
      Breach of the company’s smoking rules
      Time wasting
      Contravention of minor safety regulations
      Disruptive behaviour
      Unauthorised use of the telephone
      Absence without authority
      Unacceptable attendance levels
      Improper behaviour to customers or other members of staff

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      Unsatisfactory standard of dress or appearance in accordance with the appropriate dress code of the
       company.


Gross misconduct
Gross misconduct is a serious breach of the Company’s rules and procedures or the recognised and accepted
standards of conduct which results in a breakdown of the relationship of trust and confidence between the
Company and the member of staff concerned. Gross misconduct will justify dismissal without notice or payment
in lieu of notice and without previous warnings.
Examples include but are not limited to:

      Failure to meet legislative, regulatory or insurance company compliance requirements
      Backdating cover
      Coercing customers to, or knowingly allowing them to make false representation
      Repeated failure or refusal to perform work assigned
      Reporting for work having taken an intoxicant or non-prescribed drug and in the opinion of the
       Management, being unfit to carry our normal duties
      Fighting, provoking or instigating a fight on Company premises
      Threatening or intimidating behaviour
      Indecent conduct
      Abusive language
      Rudeness to a customer of the company
      Falsifying, changing or altering in any way, documents or records relevant to the business of the
       Company’s
      Theft, destruction or defacing of the Company’s or fellow employee’s property
      Deliberate violation of a safety rule or engaging in an activity which puts the safety of other staff members
       or customers at risk
      Divulging confidential information relating to the affairs of the Company or its customers to unauthorised
       persons
      Any breaches of the Company’s Harassment or Equal Opportunity Policies
      Dishonesty
      Serious insubordination
      Any action likely to bring the Company into disrepute
      Reckless or serious misuse of a Company vehicle
      Refusal to comply with a reasonable instruction
      Abuse of the Company’s force majeure leave procedure
      Breaches of the Company’s bullying policy
      Breaches of the Company’s computer use policy
      Abuse of the Company’s sick pay scheme
      Loading unauthorised software to any computer system
      Unauthorised use of computer data.




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Appeals

If you are dissatisfied with any disciplinary decision affecting you, you may appeal to the level of management
immediately above that at which the decision was taken within five working days of the disciplinary decision.

Appeal meetings will be heard at Adelaide’s offices unless agreed otherwise at the discretion of management.

If the disciplinary action which is the subject of the appeal is your dismissal the decision to dismiss will stand
unless it is reversed on appeal.

Any appeal must be put in writing, stating the grounds for the appeal. The appeal will be heard by an
appropriate senior manager who has not been involved in the initial proceedings.

The Appeal will review but cannot increase a disciplinary penalty.

The decision of the manager hearing the appeal is final. There is no further right of internal appeal.

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Grievance Procedure

In the event that a staff member becomes dissatisfied with some aspect of work and this dissatisfaction cannot
be readily resolved through the normal relationship with colleagues and the manager, the grievance procedure
set out below must be used.

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The objective of this procedure is to provide a mechanism whereby grievances may be speedily addressed and
resolved with access to senior management to achieve this where necessary.

Grievance hearings will be at Adelaide’s offices unless agreed otherwise at the discretion of management.

All members of staff have the right to raise any matter with their immediate manager or supervisor and, if not
satisfied with the answer received, appeal to higher management. The following procedure outlines the method
by which members of staff can exercise this basic right.

At all stages of the grievance procedure you may be accompanied by a fellow employee or a trade union official
of your choice.

The objective of all parties should be to resolve the problem at the earliest possible stage of this procedure.
Where is necessary to progress a problem through the procedure, this will be done as speedily as possible.

Stage 1

The grievance is raised in the first instance between the staff member and his/her department manager, who will
attempt to deal with the matter after making such consultations as are necessary. Every opportunity will be
given for your grievance to be stated and thoroughly discussed. As appropriate, further investigation may take
place and action taken. If the complaint or grievance relates to your immediate superior, the grievance can be
raised with the next level of management.

Stage 2

Failing resolution at Stage 1, the staff member (accompanied by a colleague, if desired) will discuss the issue
with the department manager and the senior manager with overall responsibility for the department. Within four
working days of the receipt of a complaint, the managers dealing with the grievance will arrange a meeting with
you to investigate the matter. Every opportunity will be given for the grievance to be stated and thoroughly
discussed. As appropriate, further investigation may take place and action taken. A decision will be given within
ten working days unless extended by mutual consent.

Stage 3

Should the problem remain unsolved after Stage 2, the staff member, within four days of that decision, appeal to
the board of directors. Within four working days of the receipt of the complaint, the director will arrange a
meeting with the staff member to investigate the matter (accompanied by a colleague, if desired). Every
opportunity will be given for the grievance to be stated and thoroughly discussed, as appropriate, further action
may take place and action taken. A decision will be given within ten working days unless extended by mutual
consent. The director’s decision is final and the grievance procedure is exhausted at this stage.

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Part 4                         Health, safety and security policies
                                               “Take good care of yourself,
                                               Take good care of yourself,
                                                  I’m thinking of you”

                                                     Three Degrees


Health & Safety Policy Statement

Adelaide is concerned that it shows proper and active commitment to the health, safety, and welfare of its
employees and visitors to its premises, as well as accepting its duties under the health and safety legislation.
This legislation includes the responsibility of every employee to take care of his/her own health and safety at
work and that of persons who may be affected by his/her actions or omissions.

Policy and Statement

1. Adelaide Insurance Services (the Company) accepts that its duty under the Health and Safety at Work (NI)
   Order 1978, and all other subsidiary legislation and Approved Codes of Practice, will be regarded by all
   management and staff as being of primary importance. Health and Safety will, as far as is reasonably
   practicable, be accorded the appropriate degree of attention and resources.

2. The Company is concerned that it should continue to show proper and active commitment to the health,
   safety and welfare of all its staff and to all others who may be on premises over which it has control, or are
   otherwise involved with any operation or activities of the Company.

3. An important feature of an effective policy on health and safety at work is the definition of responsibilities of
   individuals in the organisation. In general terms, responsibilities within the Company are as follows:

4. While it is accepted that the primary responsibility and accountability rests with the Executive Directors of the
   Company, the implementation of the day to day operation of the policy is vested in managers as delegated to
   them by the appropriate Director.

   4.1. The Directors have special responsibilities for the overall co-ordination of Health & Safety matters, and
        to ensure that the Company’s policy on the health and safety of its employees and others is monitored,
        reviewed and revised, as necessary.
   4.2. The Directors are responsible for ensuring the efficient management of departments under their control.
        This includes ensuring that all functions within the Company comply with health and safety legislation,
        including the issues of a suitable policy statement, and that all managers of the departments are fulfilling
        their more specific responsibilities. Each office will have an annual Health & Safety Audit. All workplace
        inspection reports carried out by inspectors authorised by the company, will be presented to all members
        of the relevant Safety Committee for that particular office for discussion within the Safety Committee.

5. The Health & Safety Statement is to be regarded as the authoritative information source for details on all
   relevant health and safety issued within the Company.

6. Managers (the term in this context is interpreted very widely to include anyone who supervises the work of
   others) are responsible on a day-to-day basis for ensuring that the policy on health and safety is observed
   and that laid down health and safety procedures are being followed.

7. This policy statement will be brought up to date from time to time as and when necessary. It will be issued to
   all employees and is supplemented where appropriate by departmental statements, outlining the organisation
   and arrangements for putting the policy into effect.

8. The Health & Safety at Work (NI) Order 1978 states that every employee has a responsibility to take
   reasonable care of his/her own health and safety at work, and that of persons who may be affected by
   his/her acts and omissions.
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Application

The promotion of health and safety measures is a common objective for the Company and for its staff at all
levels. Therefore:

1. The Company will, so far as is reasonably practicable, safeguard the physical and mental well-being of all
   staff at work. This will entail:

   a) the provision and maintenance of safe systems of work and healthy working environment;

   b) the provision of appropriate information , instruction, training and supervision in safe working methods
      and procedures;

   c) making provisions for first-aid and welfare facilities;

   d) implementing appropriate security arrangements.

   In addition it will:

   e) expect management at all levels to set an example in safe behaviour and maintain a constant and
      continuing interest in staff health and safety at work; and

   f)   nominate for each department a senior officer responsible for health and safety matters.

2. Staff should respond to these leads by:

   a) taking reasonable care for the health and safety of themselves, colleagues and others; observing safety
      rules where applicable to them; and

   b) co-operating with management in measures designed to promote health and safety at work.

3. The head of each department has executive responsibility for the management of the department’s
   operations including health and safety implication. The basis for maintaining high standards in health and
   safety is the department’s policy statement and ensuring that this is adhered to is the head of department’s
   most important health and safety responsibility. The policy statement includes specific details of the
   organisation and arrangements for dealing with health and safety matters and describes individual
   responsibilities within the department. It is reviewed from time to time and revised as necessary.


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Statement of Responsibilities

An important feature of an effective policy towards Health and Safety at work is the definition of responsibilities
of individuals in the organisation. In general terms responsibilities within the Company are as follows:

1. The Director has the special responsibility for the overall co-ordination of Health and Safety matters, and
   ensures that;

   a) the Company policy towards the health and safety of its employees and others is monitored reviewed and
      revised, as necessary.

   b) a suitable organisational framework exists to deal with health and safety at work.

   c) suitable arrangements exist and responsibilities are defined for the transition of the policy into a working
      practice.

2. All managers are responsible for ensuring the efficient management of departments under their control. This
   includes ensuring that all functions within the Company comply with Health and Safety legislation (including

2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                            Page 60 of 138
   the issue of a suitable policy statement) and that all managers of the departments are fulfilling their more
   specific responsibilities.

   All offices will have a Safety Audit carried out annually which will include a review of the implementation of
   the Management of Health and Safety at Work Regulations (NI) 2009.

3. Office managers are responsible, in particular, for ensuring that:

   a) a programme of action exists for developing and maintaining the department’s policy;

   b) progress towards meeting any objectives etc., and in maintaining standards, is monitored;

   c) any rules or procedures necessary for the healthy and safe execution of work activities are introduced;

   d) their subordinate managers are aware of their responsibilities for health and safety, and fulfil them.

   Each office manager has designated a senior officer to carry special responsibility for assisting with the
   development and maintenance of the departmental policy.

4. Each department senior officer responsible for health and safety matters is accountable to their head of
   department, within the limits laid down by this policy, for the formulation of an appropriate organisational
   framework and the co-ordination of all health and safety matters in the department. This will include making
   all reasonable practicable arrangements to secure that:

   a) all staff, and especially new employees, receives suitable training, instruction and supervision.

   b) the department complies with the Company’s undertakings and its own policy statements and any
      additions or supplements thereto;

   c) all relevant health and safety information is distributed as appropriate to managers, employees, safety
      representatives, etc.

5. Managers and supervisors have a general responsibility for work activities under their control. Within this it is
   their duty to endure that the health and safety policies and arrangements that have been made are converted
   into actions and working practices. Additional specific responsibilities may be defined in local and
   departmental policy statements. As a general rule, however, it may be taken that managers’ direct
   responsibility for health and safety is determined by the extent to which they have authority to take executive
   action within the overall limits of their job. In other words, if they have authority to make a general decision
   about some aspects of their work, then they are responsible for the health and safety implications of that
   decision.
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Use of Workstation

Make sure your seat, monitor and phone are in the correct position:

      When you are seated at your normal working position, your monitor should be right in front of you so that
       you are looking straight ahead without turning your head;
      your eyes should be level with the top 1/3 of the monitor;
      your monitor should be neither too close or too far away (25” is recommended);
      tilt your monitor – the top of your monitor should be slightly further away from your eyes than the bottom;
      if you have to use the phone often, use headphones (if you have not yet been provided with headphones,
       please ask your manager);
      avoid cradling the phone handset between your head and shoulder;
      it is recommended that the settings on your PC are set so that the colours of the text contrasts with the
       background, e.g. dark text on a light background;
      your chair height should be adjusted so that your feet can be placed flat on the floor;
      your chair back should be adjusted so as to provide lumbar support in the small of the back.

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You should also consider the following:
    that your hands, wrists, and forearms are in a row, straight, and almost parallel to the floor;
    that your head and torso are in-line with head slightly bent forward, facing towards the front, and
      balanced;
    that your shoulders are at ease with upper arms hanging normally at the sides of your body;
    that your elbows are close to your body and bent between 90 and 110 degrees.




Management recommend that all staff visit their GP, Dentist and an Optician on at least an annual basis to have
their general, oral and eye health checked. Remember, the Company Health Plan may be able to reimburse
certain costs.
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Health and Safety guidelines for the pregnant employee

Access to the Building
At all times throughout your pregnancy, we recommend that you use the lift, which can be accessed at the rear
of the premises. If, however, you feel capable of using the steps at the front of the building please ensure you
hold the handrail at all times when using them.

Breaks
Adequate breaks are provided throughout the day, although additional breaks may be granted upon referral to
the management.

Overtime
You are not required to work extra hours over and above your contracted hours.
If your Doctor recommends that you should reduce your working hours, you should inform management
immediately.

Moving/Carrying Heavy Objects
Under no circumstances should you lift/move any heavy objects whether they be on the floor, desk or from a
shelf. You should always ask assistance from a colleague.
E.g. Cartons of paper, boxes of envelopes.

Fluctuations of Temperature
From time to time you may find the office too hot or cold. Additional fans or heaters are available upon request.

Kitchen
Pay particular attention to hot water/kettles, the oven and the microwave.


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Slippery Surfaces
In winter, and as the upper terrace and car parks are not regularly gritted by the Landlord, please ensure that
you take extra care or get assistance from a colleague when crossing these areas.

Illness
During your working hours should you feel unwell, please ensure that your line manager is informed
immediately.
Your Doctor’s telephone number, together with any other person you would like us to inform, should it be
necessary, should be lodged with management.

If you feel that there are any issues relating to your pregnancy and the duties you perform, or the work
environment, please raise these matters with your line manager.
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Manual Handling

The Manual Handling Operations Regulations 1992, as amended in 2002 apply to a wide range of manual
handling activities, including lifting, lowering, pushing, pulling or carrying. Adelaide’s aim is to reduce the risk of
injury to employees from manual handling.

Adelaide’s staff members are advised to consider the following pointers to ensure safe manual handling within
the organisation:

         Think before lifting/handling
         Keep the load close to the waist
         Adopt a stable position
         Get a good hold
         Start in a good posture
         Don’t flex the back any further while lifting
         Avoid twisting the back or leaning sideways
         Keep the head up when handling
         Move smoothly
         Don’t lift or handle more than can be easily managed
         Put down, then adjust
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Fire / Evacuation

It is essential that all employees familiarise themselves with the fire exits, evacuation routes and assembly points
in the event of a fire. The guidelines for action on the event are detailed in each office, and fire equipment is
located at strategic locations in each office. Fire exits must be kept clear of obstructions at all times and fire
doors must be kept closed. Please take care that a fire is not caused by your actions.

Adelaide’s offices at Boucher Plaza, 4-6 Boucher Road, Belfast, have 6 fire exit routes marked with an arrow on
a green sign above the doors and pointing to doors:-

From Unit 3 & 4 –‘Sales Office’

         The inner and outer main entrance/exit doors through reception;
         The doors towards the front of the sales office;
         The door at the rear of the sales office exiting to the rear stairwell exit.

From Unit 6 –‘Admin Office’

         The inner and outer entrance/exit doors through the shared lobby;
         The door towards the front of the office (near Margaret’s desk);
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      The route from the main doors of the admin office exiting to the rear stairwell exit.

Keys are not required to Exit the premises through any of these exits. They are all on ‘thumb-screw’
locks from inside.


Fire Alarm

Beside each set of double-doors are red ‘break-glass’ boxes to be pressed to activate the alarm in the event of a
fire (at the rear exit, one is located at the other side of the door in the shared lobby).


Extinguishers

Located within the premises are fire extinguishers. Extinguishers are located at the following:

      at the outer doors in the main reception;
      behind the counter in the main reception;
      at the fire exit door at the front of the sales office;
      in both kitchens;
      at the double doors exiting the sales office;
      beside the comms rooms in the sales office;
      downstairs in the lobby beside the exit door;
      at the lobby between the Admin office and the main reception beside the fire exit doors;
      at the exit door to the rear of the sales office;
      in the lobby opposite the lift outside sales office;
      in the lobby of the toilets in the admin office;
      at both sets of double doors exiting the admin office;
and are highlighted by wall-mounted signs.
Employees are reminded that
      - the larger extinguishers marked Water are for wood, paper, fabric fires, etc;
      - the smaller ones marked Carbon-Dioxide must be used for Electrical or Flammable-Liquid fires.
      - a Fire Blanket is also located on the wall in each of the kitchens.


Evacuation

In the event of an alarm being raised, all staff should immediately leave the premises using the nearest
exit. Staff on the telephone at the time should advise the other party that the fire alarm has been raised and
they must terminate the call immediately. Staff at the counter must also advise the customers that the premises
must be immediately evacuated and ensure that they leave the building. Customers may evacuate and
assemble with staff if they are prepared to wait. Staff should not hinder the evacuation by collecting personal
belongings. In the event of emergency evacuation or drill, the lift at the rear of the premises must not be
used.

On the notice boards in the sales kitchen and the administration kitchen cloakroom area are copies of the office
plan, and a list of all Adelaide Employees along with a copy of the holiday calendar. In the case of a fire
management upon leaving the premises must collect these sheets for a role call to be carried out. All staff are to
assemble in the car park to the rear of Boucher Plaza at the space between the side wall and the first allocated
Adelaide parking space. Management will then check names from the log.


Fire Drills

In the event of a Fire Drill, staff will evacuate the premises using the rear exit of each unit. After evacuation,
management will ensure that unattended entrances to the premises are locked and that key-holders are
available. No one should re-enter the premises until a Premises Officer can confirm that all staff are accounted
for.
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Risk Assessment

Risk assessments are important elements in ensuring employees have a safe workplace to work in. Fire Safety
Legislation changed at the end of 2010. Annual risk assessments will be carried out on in Adelaide’s premises
and action taken as appropriate to improve the safety standards and reduce any ‘risk’ within the organisation.

A fire safety logbook will be held within the premises and a copy kept off site.

Certain employees will be trained as wardens and in fire awareness to ensure that, in the event of a fire or
accident, members of staff will be able to handle the situation.

Fire extinguishers within the organisation are serviced to ensure they are in proper working order.

Any accidents which occur within the work place are to be noted in the ‘Accident Book’ and passed to the
Human Resources Department. The Accident Book is located in the Sales kitchen beside the notice board.

Periodic electrical testing is carried out to ensure the highest safety levels are in place within our work place.

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First aid / accidents

In the event of a minor injury to you, a first aid box is available in the kitchen area of the main Sales office. If an
injury occurs to another person do not remove the injured person but contact one of the assigned first aiders or
the ambulance service.

All accidents or “near-miss” accidents must be reported to your department manager. The department manager
will record the details of every accident, however minor, and investigate all accidents so as to identify the cause
and to prevent any recurrence.

The Company does not accept any responsibility for medication taken from the first aid box without medical
supervision.

If an employee is absent due to an accident at work for three days or more Adelaide will report this to the HSE
(Health & Safety Executive) within 10 days of the incident.
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Litter / general cleanliness

Adelaide has a strict policy with regard to rubbish and waste material and is involved in maintaining a safe
working environment (see tidy desk policy)

      Personal belongings should not be left in any public area
      Personal items should not be left in the lobby areas of washrooms for long periods of time
      Crockery and cutlery should be washed, dried and stored immediately after use
      Fridges should only be used for short-term storage. Items left in the fridge at the end of the week are to
       be disposed of by the owner. In any case, items left in the fridge for more than a day may be disposed of
       by management.
      Wash your hands immediately after you use the toilet on every occasion.
      Antibacterial Hand Gel is made available in several places throughout the office.
      Staff should not continue to attend work if they suspect that they have a flu which could spread to co-
       workers.
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Smoking policy

From April 2007, it is against the law to smoke in any enclosed or substantially enclosed premises or vehicles
that are open to the public (which includes other members of our staff). Should these regulations be
contravened, individuals can face on the spot fines of £50 which can rise to up to £1,000 should the issue be
brought to Court.

The Company takes the view that smoking constitutes a fire risk and a health hazard to staff, both smokers and
non-smokers, and therefore operates a no smoking policy within the building. Smoking is not allowed within the
view of the main entrance of the office (this includes the upper tiled terrace area and near the front steps).
Smoking is also not allowed in the lobby / stairwell at the back of the premises. It is the responsibility of the
individual concerned to ensure that the smoking rules are explained to visitors to the Company.

There are no ’smoke-breaks’.

Smoking is only permitted before & after work, and during normal breaks / lunch / dinner. Any employee who
ignores the smoking rules will be treated in accordance with the Company’s disciplinary procedure.

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Consumption of Alcohol / Drugs

The consumption of alcoholic beverages on Adelaide premises is not permitted other than with the express
permission of a director of the Company. Individual possession and/or consumption on Adelaide’s premises, of
a controlled drug (i.e. an unlawful drug) or a drug which requires a prescription and which has not been
prescribed to the employee, is also not permitted. In addition, employees are not permitted to be on the
Adelaide premises or in the Adelaide work environment if they are under the influence of alcoholic beverages or
such drugs as already described herein. Such action may be deemed as gross misconduct and could lead to
disciplinary action up to and including dismissal.

If Management feel that an employee within Adelaide is putting other staff members in danger or that is it
necessary to ‘search’ the individual; then Adelaide have the right to do so legally and with care.
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Staff Conduct at Christmas Parties and Social Outings

On such occasions, all staff are expected to behave in an appropriate, mature and responsible manner, e.g. By
consuming alcohol in moderation, making safe transport arrangements and having consideration for both
personal safety and that of others.

It is also important to highlight that staff must comply with our Equal Opportunities and Harassment and Bullying
Policies whilst out of the office with the team, colleagues or clients.

Any staff member who is found to have:

      behaved inappropriately (e.g. by way of abusive or inappropriate language, by the use of physical
       violence, by causing damage to property, by using drugs etc).
      harassed, or verbally or physically assaulted another employee or client; or
      brought the reputation of Adelaide into disrepute

Such events will be subject to appropriate disciplinary action under Adelaide’s Disciplinary Procedure in the
same way as they would have been had the misconduct occurred in the office or in the normal course of
business. Such behaviour may be treated as gross misconduct and could result in dismissal.
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Dignity and respect in the workplace

Introduction

This section outlines our policy on ensuring dignity and respect in the workplace for each employee in Adelaide
Insurance Services Ltd. and provides working guidelines for the entire Company.

Harassment and bullying can undermine the confidence of those affected by it. Every employee in Adelaide has
the right to a working environment which is free from harassment and bullying. No one should have to tolerate
humiliating or degrading behaviour.

This Policy identifies the procedures for dealing with cases of harassment and bullying.

Each and every one of us has a responsibility to behave in a manner that respects and upholds the dignity of our
colleagues and to ensure that nothing in our behaviour causes offence or humiliation to others. There is a
particular responsibility on Senior Management in Adelaide to ensure that the policy is communicated and
understood.
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Commitment to dignity and respect in the workplace within Adelaide.

Adelaide is committed to creating an environment where all employees will feel valued and their skill will be fully
utilised, making the Company a place where people want to work. A working environment free from harassment
and bullying is essential to achieving this aim.

Adelaide is committed to providing a work place free from harassment and bullying, since behaviour can
interfere with an employee’s job performance, health, and undermine job security or create an intimidating,
stressful or hostile environment. It can also result in loss of self-esteem, lower productivity, absence, and
perhaps even an individual leaving the organisation.

We are committed to providing skills, training, and relevant development opportunities for employees. It is
essential that an employee’s response to harassment will not affect, implicitly or explicitly, any decisions which
would impact in an employee’s development within Adelaide.
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Harassment

Harassment is behaviour which could be reasonably described as unwelcome and offensive, humiliating or
intimidating to the recipient. It is one-sided and imposed and affects the dignity of women and men at work.

It can include actions, comments, jokes, e-mails, pictures or suggestions which can cause the recipient to feel
threatened, humiliated or offended. What one individual may be able to accept may nevertheless cause distress
to another.

Harassment includes any act or conduct against an employee if that action or conduct could reasonably be
regarded as offensive, humiliating or intimidating to an employee. Harassment can be physical, verbal or non-
verbal. It can be repeated or persistent behaviour but can also take the form of an isolated incident. It can occur
in the workplace or outside the workplace e.g. at a work related event such as an external meeting, a function or
a training programme.

Sexual harassment is unwanted conduct of a sexual nature or other conduct based in sex affecting the dignity of
women and men at work. It can include unwelcome non-verbal, verbal or physical conduct based on the gender
of the recipient.

Apart from sexual harassment, harassment that is related to an employee’s marital status, family status, sexual
orientation, religion, age, race, disability or their membership of the travelling community undermines the
commitment of Adelaide to ensure that the dignity of each of our employees is respected and therefore, will not
be tolerated.
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Bullying

Bullying in the workplace is persistent behaviour that:

      Could reasonably be regarded as aggressive, intimidating, malicious or humiliating to the recipient, and
      is unwelcome to the recipient.

Such behaviour may be verbal, non-verbal or physical and may be conducted by an individual or group against
another person or persons.

Isolated incidents of such behaviour, while to be strongly condemned, are not bullying. Only behaviour as
defined above which persists over a period of time shall be regarded as bullying.

Bullying in the workplace is not:

      ‘An isolated incident’ of such behaviour
      Exercise of legitimate management rights
      Exercise of legitimate employee rights and responsibilities.

This definition recognises that interpersonal differences and conflicts may arise in the workplace for varying
reasons and including the implementation of legitimate management practice and the exercise by employees of
their legitimate rights and responsibilities.

Inappropriate conduct which is not bullying should be dealt with through the appropriate grievance procedure.

While it is the aim of Adelaide to eliminate harassment or bullying from our organisation, we have procedures in
place to deal with instances of bullying or harassment fairly and efficiently. This commitment to employees
extends to protecting an employee who is the victim of such conduct and who has reported in good faith their
experiences to other colleagues or managers.

The possible victimisation of an employee, who is treated less favourably than another because he / she has
made a complaint of bullying or harassment, will be carefully monitored. Victimisation could include a
deliberately inaccurate performance appraisal or exclusion from career opportunities. No employee will suffer
further as a result of reasonable actions taken by them to combat any bullying or harassment which they have
experienced.
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Legislation

Harassment, bullying and victimisation can be unlawful and can contravene employment equality and health &
safety legislation.

      Sex Discrimination (NI) Order 1975
      Fair Employment and Treatment (NI) Order 1998
      Race Relations (NI) Order 1997
      Disability Discrimination Act 1995
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What should you do about harassment or bullying?

The most important thing is that you do not ignore the problem or blame yourself. You should keep a note of the
incidents; where, when, what took place, any witnesses and copied of written material. You should also consider
speaking, in confidence, to your manager, human resources or a work colleague. These people can offer
support and help in approaching the person by whom you feel harassed or bullied.

The procedures outlined below are used where management becomes aware of an issue of harassment /
bullying. Once aware that there is an issue the procedures require management to take action, either informal or
formal.
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Procedure

The following policies have been introduced to raise general awareness of this subject amongst all employees
and to enable employees who believe they have been the subject of bullying to seek support and/or advice and,
if applicable, to take further action. An employee can always refer issues relating to bullying to his or her
manager.

Please note that the following policies may be amended from time to time at the discretion of the company to the
particular circumstances of the complaint.
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Informal Procedure

An informal approach may often resolve matters at an early stage and therefore avoid a lot of conflict and stress
for the individuals concerned. As a general rule, an attempt should be made to deal with allegations of bullying
and harassment as informally as possible.

In the first instance, you should ask the person who is harassing or bullying you to stop. Make it clear that
his/her behaviour is unwelcome and offensive and that you wish it to stop. You may feel more comfortable
communicating these feelings in writing, rather than discussing these issues face to face.

You may seek the assistance of a colleague or your manager in approaching the alleged perpetrator. The
person who assists you in this way should be non-confrontational in their approach to the alleged perpetrator
with a view to trying to resolve the matter in a low-key manner.

If you are not confident about making a direct approach as already outlined or it is not appropriate to discuss the
matter on an informal basis, or if you have done this and the behaviour continues, you should inform your
manager of what has happened. A decision can then be made, if appropriate, for the matter to be progressed
through the formal procedure as set out below.

If the complaint relates to your manager, or you feel uncomfortable making the complaint to your manager, then
you should bring the complaint to the attention of another manager.

Once a complainant has reported alleged harassment/bullying to management, action (either informal or formal)
must be taken. In the event of the complaint being withdrawn or discontinued by the complainant, the issue
may, nonetheless, be investigated in the interest of each party involved.

If is recommended that the employee who is the subject of the bullying may wish to keep personal notes of all
events from the first instance. Such notes should be shared with the appropriate manager at the appropriate
stage if the matter proceeds to the formal stage.
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Formal Procedure

It is recognised that complaints should be dealt with through the informal procedure. In cases where an
employee believes that an informal complaint is not a suitable means of addressing his/her concern, or where
the employee believes that their previous recourse to the informal complaint procedure has been unsatisfactory,
the employee may make a formal complaint. In cases where an employee makes an informal complaint but,
where the management believes (because of the gravity and/or seriousness of the subject matter of the
complaint or for some other reason) that the informal complaint procedure is inadequate to address the
complaint, that complaint may be dealt with using the formal procedure.

The complainant will be required to submit a formal complaint in writing to your manager If the complaint relates
to your manager, or you feel uncomfortable making the complaint to your manager, then you should bring the
complaint to the attention of another manager. The complaint should be confined to precise details of the
alleged incidents, including the dates of such incidents and the names of any witnesses.

On receipt of a formal complaint, an investigator will be designated by management. In exceptional
circumstances, if either party has an objection to the designated investigator, management may designate an

2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                           Page 69 of 138
alternative investigator. Any objection to the designated investigator must be made in writing to management
and must clearly outline the grounds of the objection.

Where a formal complaint is made but the complainant declines to submit a written statement, then a written
record will be made of the complaint by the designated investigator. The complainant will be asked to sign this
record.

The procedures to be applied for all formal complaints are as follows:

The investigation will be governed by terms of reference which will include the following provisions:

      -    a provision to the effect that the investigation will be conducted in accordance with this policy;
      -    an indicative time-frame for the completion of the investigation;
      -    provisions relating to the scope of the investigation, indicating that the investigator will consider whether
           the complaint falls within the definition of bullying or harassment at work and whether the complaint has
           been upheld.

         The investigation will be carried out expeditiously commencing normally within ten working days of the
          decision to commence a formal investigation with due regard to confidentiality and ensuring fairness to all
          parties involved. Subject to this, both parties will be provided with copies of correspondence and witness
          statements.

         It may be decided that it is appropriate to suspend the alleged perpetrator(s) pending the completion of the
          investigation. It may also be decided to temporarily transfer one of the parties concerned or change the
          reporting relationship e.g. if the complaint is made against the individual’s superior.

         The investigator(s) will be required to meet with both parties who may be accompanied to meetings by a
          work colleague. More than one meeting may be required on order for the investigator(s) to establish all of
          the facts relating to the complaint.

         The investigator(s), taking due cognisance of the list of potential witnessed suggested by both parties (if
          any), may also require to meet with, and take written statements from other persons, for example,
          employees who witnessed certain incidents or behaviour.

         The outcome of the investigation will be conveyed in writing to both parties. Both parties will have the
          opportunity to comment on the findings of the investigator(s) prior to any action being decided upon by
          management. However, there is no right of appeal against these findings.

         If, following the investigation, the complaint is upheld, appropriate action, including disciplinary action, will
          be taken. Where disciplinary action is taken at this stage, a further investigation under the Disciplinary
          Procedure will not be required. If the perpetrator is not an employee (e.g. a client) other appropriate
          measures will be taken. Other appropriate action may be taken to support and protect the victim and/or
          ensure that similar situations do not arise in the future.

         It will not always be possible for the investigator(s) to reach a conclusion which definitely comes out in
          favour of one party.

         If the complaint is not upheld but the complainant is found to have acted in good faith, management may
          take appropriate measures to support both the complainant and the person complained against. This will
          include the making of appropriate efforts to ensure that anyone with knowledge of the complaint is made
          aware that the complaint was not upheld.

         Where a complaint is not upheld and is found not to have been made in good faith, the complainant will be
          the subject of disciplinary action.

         If either party is dissatisfied with the outcome of the formal complaints procedure, they may lodge an
          appeal within 7 days of receipt of notification of the outcome of the process. The reason for the appeal
          should be outlined in writing to management. The appeal will be heard by another person, of at least the
          same level of seniority as the original investigator. The appeal will focus only on the aspect of the case
          cited by the appellant as being the subject of the appeal.
2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                                   Page 70 of 138
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What should you do if you are accused of harassment or bullying?

If a colleague speaks to you and indicates that your behaviour is inappropriate, you should consider this
seriously.

Do not become hostile or aggressive. Try not to automatically reject the complaint out of hand but instead, listen
carefully to what is being said. Consider whether the matter might be resolved by modifying your behaviour
accordingly. You should also consider whether your behaviour may have caused offence and if so, it would be
appropriate to offer an apology.

If you dispute the accusation being made then you will have the opportunity to present your account of the
matters complained of in accordance with the procedures as outlined above.
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Malicious or vexatious claims

If, following the investigation, it transpires that the complaint was malicious or vexatious, appropriate disciplinary
action will be taken against the complainant in accordance with Adelaide Insurance Services Ltd. procedure.

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Management responsibility

Management has a particular responsibility to ensure that all employees can perform their work, free from
harassment, bullying, and intimidation. Immediate action will be taken should any breach of this policy be
reported or observed.
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Individual responsibility

Each and every one of us has an individual responsibility to ensure that nothing in our attitude, behaviour or
actions causes offence to a colleague or causes them to feel threatened or humiliated.

Consider the following:
    Would I like this said or done to myself or a member of my family?
    Is what I am saying/doing likely to cause offence?
    Is what I am saying/doing in breach of this policy?
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Equality through diversity

Introduction

This document outlines Adelaide Insurance Services Ltd. policy in equal opportunities in the workplace for all
employees.

The aim of the policy is to achieve equality of opportunity by managing diversity. The concept of diversity is
based on recognition that a modern workforce comprises a diverse population of people having different
characteristics such as religious belief, political opinion, gender, marital status, sexual orientation, age, race,
disability, background etc.

As a Company we believe that by valuing and promoting diversity, we are fostering a climate where people enjoy
work because of the challenges and personal development they will receive.
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Managing diversity

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The achievement of equality of opportunity depends on preventing the occurrence of discrimination in the
workplace. As a Company we do not treat employees differently nor do we impose job requirements by having
regard to characteristics such as religious belief, political opinion, gender, marital status, sexual orientation, age,
race, disability, background etc. We value diversity by encouraging individual contributions and the development
of employees so that they can fulfil their potential thereby maximising their contribution to the organisation.

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Workplace discrimination and the law

Adelaide Insurance Services Ltd. recognises its obligations under:

       Sex Discrimination (NI) Orders 1976 and 1988
       Equal Pay (Northern Ireland) Act 1970, as amended
       Fair Employment & Treatment (NI) Order 1998,
       Disability Discrimination Act 1995
       Race Relations (Northern Ireland) Order 1997.

In accordance with the Acts, Adelaide Insurance Services Ltd. will not discriminate on the grounds of religious
belief, political opinion, gender, marital status, sexual orientation, age, race, disability, background etc.

Harassment on each of these grounds is also prohibited under the Acts.
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Recruitment, selection and promotion

The aim of any selection process is to source the right person for the job. It is our policy to ensure that this
process is fair, professional, and unbiased in its approach.

This means that the selection process must provide equal access to all who meet the selection criteria and that
Adelaide Insurance Services Ltd. will not discriminate – directly or indirectly – on any of the grounds specified in
any of the acts referred to above.

       When advertising vacancies, the language chosen to describe the position(s) will not be discriminatory,
        thus ensuring that all prospective candidates who meet the selection criteria are clear that they have
        equal opportunity in the selection process.

       Part of the selection process (for internal vacancies as well as external recruitment) usually includes
        conducting interviews. In assessing candidates, interviewers will not imply discrimination by asking
        questions about personal, family or other circumstances which are unrelated to the requirements to do
        the job. We will ensure that those involved in conducting interviews will be briefed thoroughly on
        complying with this policy.

       Where it is necessary to assess whether personal or family circumstances will influence an individual’s
        ability to do a job effectively, e.g. mobility or transferability, this should be discussed objectively and in a
        similar way with all candidates.

       We recognise that, while lack of mobility may be a factor at a certain point in a person’s career, it should
        not be assumed that this will always be the case.

       Selection criteria will be regularly reviewed to ensure that Adelaide Insurance Services Ltd, is not
        discriminating against any group of employees.

       Discussion on future career prospects/advancement and encouragement for future development will be
        available to all staff.
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Career and personal development


2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                                Page 72 of 138
Adelaide Insurance Services Ltd aims to foster and support a work culture which promotes equal opportunity to
all employees in relation to career and personal development.

All employees will be encouraged equally to undertake self-development and training in order to compete for
promotion. It should be assumed that all employees are interested in progressing their careers or receiving
opportunities to do so unless they expressly indicate otherwise.

It is important that nominations for training courses reflect the appropriate development of skills for all categories
of employees covered by the policy.
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Performance review and feedback

It is the policy of Adelaide Insurance Services Ltd that the Performance Review and feedback (appraisal)
process be conducted in a non-discriminatory way. This means that:

      all performance review meetings should be planned to follow the structured guidelines on conducting the
       review process

      discussions should not be discriminatory in tone or content

      the documentation to support the process should be job competence, performance, career and
       development focused

      all staff should be given encouragement to consider themselves for job/promotional opportunities for
       which they have relevant experience and ability

      it should not be assumed that family commitments lead to limited career aspirations

      all staff should be presented with equal access to training which is relevant to their job.

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Use of language / illustrations in internal and external group documents

Adelaide Insurance Services Ltd. wishes to promote its philosophy of equality generally through all its publicity
and marketing material and internal forms/documentation, for example, training literature, application forms.
Whether through words or illustrations, such documentation should not be discriminatory – either directly or
implied.


Combining work and life responsibilities

We recognise that staff with outside responsibilities may, at certain times in their careers, have greater difficulties
combining work with these commitments. With this in mind, we are continually examining initiatives which
facilitate such responsibilities having regard to business requirements.

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Breaches of the policy

If an employee feels that this policy is being contravened then they should inform an appropriate manager.
Furthermore, if an employee believes that they have been or are being discriminated against contrary to this
policy then they are entitled to pursue their grievance in accordance with the published grievance procedure.

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2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                             Page 73 of 138
Part 5                                       IT & Facilities policy

                                            “Take a look at the toys around you
                                                  Right before your eyes
                                                     The toys are real”

                                              Computer god – Black Sabbath


Computer Use Policy

Scope and Objectives

This Policy applies to all Adelaide Insurance Services employees, temporary staff, contractors and consultants
who use Company computing hardware and software. It details the Company’s position with regard to computer
security and user responsibilities to ensure the Company systems and information are secure and run smoothly
and all relevant legislation is complied with.

There are various pieces of legislation that impact on or can be breached through the use of computer, email
and Internet applications including those relating to copyright, data protection, defamation, harassment and
criminal law.

The Disciplinary and Equal Opportunities Policies can both be relevant to the use of Computer and Internet
applications. Non-compliance with this policy will lead to disciplinary action, and in some cases, dismissal (see
Company’s Disciplinary Procedure).

Responsibilities of staff

All users are responsible for:

      Ensuring they fully comply with this policy;

      Ensuring only authorised personnel use their computer;

      Undertaking regular file and e-mail house-keeping, e.g. backups, deleting obsolete files, etc;

      Ensuring your total mailbox size is kept under 100 MB (Megabytes) or 100,000 KB (Kilobytes);

      Shut down completely your computer (or the one you have been using) every night when you leave;

         o       The only exceptions are:
                  Managers, Department Heads, or senior staff where you have set a report to run at end of day
                    which would take some time to finish (in which case the ‘Lock Computer’ protection should be
                    activated);
                  The pc’s at the counter;
                  The CDL MIS pc;
                  The pc linked to the ActinTime clock-in terminals.

      Always leave your pc screen ‘locked’ when unattended. It is a requirement from our I.T. Computer Use,
       Internet and Email policy that staff lock their screens when leaving their desk. This can be done by
       Ctrl+Alt+Del then select ‘Lock Computer’. This is particularly important if you leave your desk for more
       than a few moments. PCs can be set to lock automatically when it hasn’t been used for a few minutes,
       so that your network password is required to unlock it. Follow the simple instructions:

                 Start (bottom left of screen)
                 Control Panel
                 Display
                 Screen Saver
                 Set to Wait: e.g. 2Minutes, tick box at on resume, password protect
2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                          Page 74 of 138
            Apply
            OK

      Reporting to the Operations Manager any viruses or breaches of policy;

      Taking appropriate care of all computer equipment assigned to them, e.g. PC’s, scanners, printers,
       laptops;

      Never leaving computer equipment (e.g. laptops) unattended in public places or visible in a car.

      Staff are banned from bringing in appliances which have not been tested, as there is a possibility that it
       might carry a virus which could get into our computer system;

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Departmental managers are responsible for:

      Monitoring use of computers;

      Addressing issues of misuse;

Senior managers are responsible for:

      Communicating this policy and the procedures that are linked to it, and monitoring compliance;

      Assisting with the investigation of issues of misuse;

      Reducing the threat of virus infection by ensuring effective security is in place at all times.
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Hardware / Software

Only Adelaide Insurance Services authorised hardware and software is to be connected to the Adelaide
Insurance Services network by the I.T. department from Head Office.
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Copying of Software

The Company has a legal obligation to ensure that all users comply with copyright regulations. Therefore:

      Software or accompanying documentation must not be copied or distributed without licence from the
       copyright owner
      Shareware software must not be downloaded onto Adelaide Insurance Services computers
      Software must be used in accordance with the relevant licence and will specify the number of users and
       may specify the particular machines on which the software may be issued. If you are unsure, contact I.T.
      Users must not distribute or encourage other users to make or distribute illegal software copies sourced
       either from Adelaide Insurance Services or users’ homes
      Only IT can install licensed software. Users must not install software.
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Passwords

Users are responsible for the use of the network accessed through their user-ID and password.

Password guidelines:
    It is your responsibility to keep your password secret;
    Do not share your password or write it down where others can see it;
    Do not use anyone else’s user ID or password;
    Always ‘Log-Off’ or ‘Lock Computer’ before leaving your computer unattended, so that the password must
      be re-entered to gain access;
2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                                 Page 75 of 138
      Use a password-protected screen-saver which activates automatically when pc not used for a few
       minutes.

If your absence due to holidays or illness could prevent access to important computer systems or records, you
should seal your passwords in an envelope and hand it to the Operations Manager to be locked away. You
should include all sign-on passwords, PC power-on passwords, screen-saver passwords, and spreadsheet /
document passwords which may be necessary. A manager will tell you if a password has been used in your
absence, in which case you must change it immediately on your return to work.
OR
All employees’ data held on computer and network files can be accessed by authorised personnel without the
use of password credentials.

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Storage of Files / Housekeeping

Housekeeping should be conducted on at least a monthly basis and any files no longer required should be
deleted.

It is the responsibility of the user to ensure that any data stored to any areas (other than the network /Public Z
folder) is backed up regularly, e.g. the hard drive on your PC.

Users are not permitted to store sensitive or official data on their local hard drive of their PC’s.
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Virus Controls

A virus is a computer program which hides in other programs and can cause a great deal of damage. A virus is
spread whenever information is passed from one computer to another, e.g. through disks, USB storage devices,
CD’s and computer networks. Viruses can sometimes lie dormant for a considerable time before causing havoc.

Computer viruses are a growing concern for our business. Therefore:

      Any data you may wish to use from an external source (disk, USB storage device, CD, internet, or e-mail)
       must be authorised by the Operations Manager or Director and virus checked before being loaded onto
       machines;
      All viruses should be reported to the Operations Manager.

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Data Protection

Personal information is any information which includes a fact or opinion about a living person. The Data
Protection Act covers all personal data kept on electronic files. Any information of this kind should only be
disclosed to authorised personnel with a legitimate reason. If you are unsure about disclosing personal
information, check first with your Manager. Unnecessary personal data should not be retained or filed.

The maximum penalty for failing to meet these obligations is an unlimited fine. You can be held liable, in
addition to any liability on the part of the Company.
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Internet / Email Policy

Introduction

The internet is a growth area for the Company. It has opened up a new channel of communication which we can
use as a business tool in marketing or servicing our group schemes and individual plans. Utilising the Internet
as a business tool necessitates that authorised staff should become familiar with those techniques and practises
used to properly communicate, retrieve and disseminate relevant information via this medium.
2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                               Page 76 of 138
The Corporate electronic messaging facility / E-mail provide personnel with access to internal and external E-
mail. There are risks associated with the use of internal and external E-mail. This policy outlines the
responsibilities of every member of staff with respect to the use of the Company E-mail system.
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Scope

The Internet and E-mail policy applies to the Company, employees, suppliers and contractors who access the
Internet medium via the Company’s computing facilities and/or the E-mail facility. Any concerns or questions
you may have in respect of this policy document should in the first instance be relayed to your line manager.
You may also contact the Operations Manager or the Compliance Manager to seek clarification on any issue.
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Policy Objectives

The objective of the Company Internet and E-mail Policy is to help:

      Provide secure and controlled access to the Internet from a desktop PC;
      Ensure the Information Systems of the Company or Group are in no way put at risk;
      Define statutory responsibilities in relation to National and International legal requirements governing
       electronic information exchange and commerce;
      Define standards of use for E-mail within the Group;
      Define the course of action to be adopted should there be any contravention of the procedures, rules and
       guidelines outlined in this policy.
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Internet Security

The I.T. department is responsible for enabling, monitoring, analysing and archiving of all technical data in
relation to the Company’s Internet connections. This entails monitoring of internet usage and at their discretion,
placing restrictions on Internet sites that could be categorised as racist, pornographic, etc.
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Internet Legislation

It is illegal to knowingly possess, produce, distribute, print, import, export, sell or show any child pornography.
Breach of the Company’s internet and e-mail policy in this regard will result in appropriate disciplinary action.


Internet and e-mail access control

Users with legitimate business reasons may obtain access to the internet. All internet access is monitored and
logged.

      The Operations Manager or Director of Adelaide Insurance Services will authorise access for approved
       personnel.
      All connections from Company computing devices to the Internet must be via the Firewall route only – no
       other means of connectivity is permitted, i.e. dial-up connection from desktop PC’s etc.
      Company Laptop Computers or Netbooks must not be used for Internet access outside the office without
       prior authorisation from the Operations manager or Director.
      Personnel will be accountable and responsible for all actions carried out under their Logon ID/ Username
       & Password.
      Giving other persons access to systems via your Logon ID / User Name & Password is a serious breach
       of Company Policy and will result in appropriate disciplinary action.




2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                             Page 77 of 138
Out of Office Assistant

When staff members are off work, even for a few days, emails sent by customers directly to staff can be
overlooked or may not receive a prompt response. Mailboxes can also quickly reach their limits and reject all
further e mails, and this can in turn lead to customer service issues.

If your going to be off for a full working day for more, you must set your Out of Office Assistant with Rules to
Delete certain emails and auto-forward certain e mails to your line manager (or to your team or to another
member of staff approved by your line manager e.g. if your line manager will also not be available)

    Step 1 – Out of Office Assistant;

When in Outlook, Tools, Out of Office Assistant, turn on ‘I am currently Out of Office’ just before you leave with a
simple clear businesslike message. It should just say you’re off, when your back and who to contact in
meantime. It doesn’t need to say from when you’re off, nor where you’re going. Below is an example:




Always remember to hit OK before exiting each window.


    Step 2 – Add rule to delete emails sent to our commonly used email distribution groups which you are a
     member of;

In the Out of Office Assistant, click on ‘Add Rule’ button at the bottom left

Set up first rule to delete e mails sent to your team name, e.g. IAM. Select ‘sent to’ then select the appropriate
team names that you’re a member of, then tick the box at ‘delete’, then ‘ok’. Do not select to forward these
where your line manager will already be getting them.

See example below:




2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                            Page 78 of 138
    Step 3 – Add rule to Forward emails sent directly to yourself;

In the Out of Office Assistant, click on ‘Add Rule’ button at the bottom left

Set up this record rule to Forward emails which are sent directly to you as shown below. Tick box at ‘Sent
directly to me’. Then tick the box at ‘Forward’ and select to and select the name of the person you want to
forward your e mails to.

See example below:




2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                         Page 79 of 138
   -   Always remember to hit ‘OK’ before exiting each window.

These rules will be effective when the Out of Office Assistant it turned on, and they will not operate when you
turn the Out of Office Assistant off when your return to work. Once these two rules have been set up they will be
there for you the next time you need to turn your Out of Office Assistant on so saves time writing it out again.

You can select and deselect the rules independently from the Out of Office Assistant using the tick box at
‘Status’ at the bottom, but this should rarely be necessary.




You should not be receiving personal emails to your work email e.g. from friends or family.

You can check what e mail groups you are in by opening a new e mail, hit ‘To…’ select your own name from the
internal contact list, right-click on your name, select ‘properties’, then ‘member of’ and this should show the
groups you’re a member of. You should only apply the delete rule for e mails sent to….. the groups that get the
daily bulk i.e. you won’t want to return to a week’s worth of online registrations as these should have been dealt
with the by the rest of the team at the time when you had been off.


Internet – Standards of Use

      Work-related Internet sites should be the focus of Internet browsing.
      Access to the internet through Company computer network (including any remote PC which is the
       property of the Company) is for business purposes.
      Adelaide has a pc and broadband connection which is not on the main network. This is for personal
       internet browsing by staff before work, during breaks and after work. Such use should not cause the
       Company to incur any costs.
      Internet sites of any unsavoury, obscene, hateful, objectionable or pornographic nature are prohibited.
      The history of visited sites on office pcs will be automatically recorded.
      The IT Department will scan and monitor Internet Browsing at their discretion.
      File download / transfer (FTP) will be enabled for the IT and Operations function alone.
      All requests for file transfer (FTP) should be routed to the Operations Manager.
      Information provided on the internet should never be relied upon and always verified with another source.
      Information including reference or hyperlinks about the Company (or any part of Cornmarket Group
       Financial Services Ltd or the Irish life Group) must not be discussed, posted or published by staff, on the

2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                          Page 80 of 138
       internet in any form, without the appropriate approval – contact Adelaide’s Operations Manager or the
       Director for advice.
      The standard Internet Browser is Microsoft Internet Explorer –it is not permitted for staff to install a beta
       or test browser as their default internet browser.
      Users should not create or post indecent remarks or material on the internet.
      When an employee introduces material into the Company network, they are considered to have
       originated this material. Origination of material includes:
           o Downloading material from the internet;
           o Copying material to and from CD-ROM, diskette or USB storage device;
           o Introducing material through another device on the network (for example a scanner);
           o Creating the material on a PC.
           The origination of inappropriate material in the Company network is a serious disciplinary
           offence that may result in suspension of employees.
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E-mail – Standards of Use

      E-mail is a business tool and should be used as such. It is not considered private or confidential. All E-
       mail content, volume and size may be monitored by the I.T. department at their discretion. All e-mail is
       stored and the Company reserves the right to inspect it at any time without notice.

      The Company reserves the right to withdraw e-mail without explanation.

      Employees are responsible for all e-mail sent using their Logon ID. Any unauthorised use of another
       employee’s e-mail will be subject to disciplinary action.

      All e-mail is to be written in accordance with the standard of any other written communication; the content
       and language used must be carefully addressed to ensure that it reaches the target recipient.

      Confidential, secret or competitive sensitive information must not be communicated externally without
       authorisation from senior Management. Such information should not be sent via the e-mail system – all
       such e-mail is transmitted over an insecure public network – this could compromise the privacy of the
       communication.

      Whether internal or external to the Company, messages must not contain inappropriate material.
       Inappropriate material is that which may be judged to be defamatory, discriminatory, obscene, illegal or
       otherwise capable of causing offence to any employee or third party, on the basis of sex, race or
       disability etc. Breach of this rule is a serious disciplinary offence which may result in suspension
       of employees.

      The e-mail system must not be used for the distribution of unsavoury materials, indecent, obscene or
       libellous material. Games and chain mail – including jokes, rumours, gossip and hearsay etc – must not
       be sent or forwarded via e-mail – Respect and treat the Company e-mail system, the same as you
       would the Company notepaper!

      Employees must not subscribe to mailing lists or mail services without the consent of their line manager
       or the Operations Manager.

      E-mail must not be used for conducting illegal activities or for profit activities not sanctioned by the
       Company.

      Copyright material should not be sent, received or copied via e-mail. All information and data collected /
       filed / stored via e-mail must be used and stored in accordance with the Data Protection Act. If you are
       unsure as to your obligations under such legislation, contact the Operations Manager or the Compliance
       Manager.

      Distribution of advertisements, mail-shots or product material via external mail must be authorised by the
       Compliance Manager or Operations Manager in advance.

      Consider carefully what you write; it’s a permanent record and can be easily forwarded to others. Read
       your e-mail before you send it, be sure you make your point clear and concise and use spell check.
2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                             Page 81 of 138
      If you receive unintended e-mail it is vital that you alert the sender by reply. Should the e-mail contain
       confidential or sensitive information, you must not disclose this information to any other group or
       individual.

      When forwarding messages, put your comments at the top of the message.

      Should e-mail received by you contravene Company Policy – you should inform your Line Manager or a
       senior Manager immediately.

      All attachments received should only be opened when employees have first checked the authenticity of
       the sender and validity of the attachment. All other attachments should be deleted or referred to the
       Operations Manager for clearance.

      Employees are not permitted to send e-mails of a personal nature from Adelaide’s e-mail address; they
       can do it from their own Gmail account, if employees are found to be committing this offence they will
       face disciplinary action.


Use of Internet and Social Network sites by employees

Adelaide will not tolerate employees mentioning/referring to work or work-related issues over the internet i.e.
social networks: this could bring Adelaide into disrepute. Employees found guilty of committing this offence will
be subject to disciplinary proceedings.

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2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                           Page 82 of 138
Control & Protection of Confidential Information

In the normal course of your duties during your employment with the Company, you will be aware of confidential
information relating to business, customers, and affairs of the Company, its subsidiaries and associate
Companies. You must therefore take responsibility to keep with complete secrecy all confidential information
entrusted to you and undertake not to divulge this information in any manner to any person or organisation not
authorised to receive this information.

This applies both while in the employment of the Company and following its cessation. You are advised in your
own interest that, where you are in doubt concerning whether or not the information is confidential, you must
seek approval from a senior manager or the Director prior to releasing any information. A copy of the
Company’s ‘Confidential Information Clause’ is detailed below.

You must take care when disposing of paperwork and other company records. Any medium to be disposed of
which contains personal, sensitive, or confidential information relating to customers, potential customers, staff, or
any other business contact – must be properly destroyed. Paper records containing such information must be
placed in the shredding cabinets.

Serious or repeated breaches of this policy may involve sanction under the disciplinary procedure.

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Confidential Information Clause

This section summarises the Company’s rules and policies with regard to the protection of the Company’s
confidential information and business.

Much of the Company’s work is of a strictly confidential nature. The Company’s business depends on ensuring
information relating to the Company’s business and systems and that of its clients is protected. Further, the
Company has a reputation for conducting its business in a responsible and ethical manner. All employees are
expected to protect such confidential information and in their actions demonstrate their respect for the
Company’s corporate values.

You are therefore requested to read this section on protecting the Company’s business very carefully, to ensure
that you understand its significance and you do nothing that will undermine the company’s business.

If there is any doubt in your mind about security matters you should immediately seek the advice of
management.
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Media Policy

Comments to Press/Media

You shall not be permitted to discuss with the press or other media, issues concerning the Company and its
activities unless you are appointed as an authorised spokesperson for the Company or you have been given
specific permission to comment on any such matter. You may not comment to the press/media about any matter
pertaining to the work that the Company undertakes or any of its clients without the express permission of the
Director or his absence the Operations Manager of the Company.
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Personal Property

It is the responsibility of staff members to minimise risks to their personal property within the office and to take
sensible precautions in this respect. The Company cannot be liable for any loss or damage to property which
may occur. Please advise your Departmental Manager immediately if you suffer any loss.

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Clear Desk Policy

To secure against after-hours fire / smoke /water damage, to enable weekly cleaning, and to ensure that
confidential information is not viewed by unauthorised people, staff members must ensure that their desk is
cleared of all files and confidential documents on leaving the office at the end of their working day.

Valuable documents and records must be secured in an appropriate fire-resistant cabinet or safe. In the event of
any doubt regarding the appropriate action to be taken with any documents, staff members should consult with
their department manager.

The following should be adhered to:

      Desktops should be clear of paperwork before staff member leaves work each day;
      Drawer units with a single small drawer for each member of staff are located in the office for the overnight
       storage of stationary items which you use daily, e.g. Pens, calculator, stapler, staple-remover, highlighter,
       notepad;
      After you leave your workstation, desktops should only contain computers, phones and scanners;
      Paperwork should be stored overnight in relevant cabinet;
      You should not store anything windowsills, floors, chairs, or in the pc tower-unit holder under your desk;
      All paperwork relating to clients must be treated with the utmost care and be kept in an organised
       fashion. Client-related paperwork must be stored overnight in the relevant department cabinet;
      Shredding bins should be used for waste paper containing confidential client/Company information;
      Keep your workstation (and unmanned workstations near you if any) clear and tidy – e.g. avoid littering
       staples, elastic bands, scraps of paper.

   Both Sales and Administration offices have drawers for storing essential items which are used on a daily
   basis (e.g. pens, calculator, stapler, stables, stapler-remover, highlighter, ruler, and notepad). These items
   should not be left on your desk or chair when you leave. The drawers must not be used for storing any
   client-related paperwork/notes, client lists, receipts, payments / payment details. Client related paperwork
   (along with envelopes, leaflets, and other general stationery) is to be stored overnight in the roller-fronted
   cabinets located at each department.

Serious or repeated breaches of this clause may involve sanction under the disciplinary procedure.

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Security of Office, Office Property, Money

Boucher Plaza Security

The gates to the rear car-park are to be locked after the last person removes their vehicle each day. This is
usually done by Donnelly Honda or an agent appointed by the landlord. The gates on the front car-park are to
be locked after the last person leaves. This is usually done by an agent appointed by the landlord. If you
unlock/open the gates after work, you must close/lock them after you leave.

The gates on the steps to the first floor must be secured by a chain and padlock by the last key-holder to leave
the offices exiting by the upper floor. The first person entering the premises by unlocking the padlock must
ensure that the locks are secured from unauthorised persons (i.e. keys are not left in locks / combination digits
are not left visible).
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Office Security

Key holders must not leave any office keys or access-fobs unattended at any time. Door key holders who are
the last to leave the building must ensure that the office is secured. This involves making sure all windows,
doors (internal also), and roller shutters are closed (and locked where applicable).

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The alarm must be set when leaving the premises. The alarm code must not be disclosed to anyone other than
current Adelaide key holders.

Codes for security doors unlocked by keypad must not be disclosed to anyone other than current Adelaide staff.
Security doors must not be propped open.

The office is equipped with Panic buttons linked to the alarm. The location of these buttons will be advised to all
staff. By pressing the buttons, a signal will be sent to the police to request assistance.

Care must be taken to minimise false alarms, e.g. Caused by an unsecured window or door, or panic button
being depressed unnecessarily.

Cameras which monitor the car parks, front steps, and counter must be kept clear of obstruction.

Staff must ensure that any customers calling at the counter wearing a crash-helmet remove it before being
attended to.

The comms room door which is situated in the sales office must always be kept closed and locked when the
room is not in use. This is an internal Audit requirement and part of IT Security policy.
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Wastage policy

Waste levels are kept to a minimum within Adelaide. Wastage of work resources, phones and stationery etc will
not be tolerated. Employees are to respect this and make every effort to limit the waste levels within the
company. Staff members are liable to reimburse Adelaide for any loss incurred if management determine that
unnecessary wastage has occurred.

It is Adelaide’s policy to operate a ‘paperless’ office as much as possible and to assist with this goal, it is
expected that staff email insurance documents to customers where possible. This provides a quicker turnaround
of service to customers and reduces paper waste, printing costs and postal costs for the company.

Items which have to be posted should be sent Second Class unless otherwise authorised by management. If all
options have been exhausted and staff feel that an item must go by first class mail, Sales advisors must gain
authorisation from the Sales Manager and Administrators from the Operations Manager. If either manager is not
available, sales advisors must gain authorisation from the sales Coordinators, and Administrators from their
Department Head. Please ensure all exceptions are valid.
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Money

Money must not be left unattended at any time. Staff must always count cash payments taken at the
counter in front of the customer, before leaving the presence of the customer. Money to be stored before
lodgement, even for short periods, must be kept in the safe. Staff responsible for safe keys (‘cashiers’) must
ensure that the keys are not left unattended and only handled by authorised personnel.

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Important Documents & Cover Note Books

Cover note books must be stored when not in use in the safe as it is also a fire-resistant cabinet. Staff
responsible for safe keys (‘cashiers’) must ensure that the keys are not left unattended and only handled by
authorised personnel.
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Car-Parking Facilities

Car parking in the front car park is for customers only. Saturdays during trading times are no different.
Employee parking (we have 6 spaces in our current lease) is at the rear. Please park responsibly and carefully
to ensure best use of the spaces. Avoid blocking the rear emergency exit and the loading doors of other
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tenants. The landlord monitors this, and if staff do not park responsibly or access or car-parking becomes
difficult for other tenants, the landlord may insist that Adelaide may only park 6 vehicles at Boucher Plaza. The
6x spaces for Adelaide will be assigned to senior management and to staff authorised by senior management.
Otherwise parking is first-come-first-served.

If you cannot get parked in the rear car-park – you must not park in the front car-park during office hours
– you must park off Boucher Plaza.

NB: if you find a delivery vehicle blocking access to the rear car park and you have to initially drive into the front
car-park, you must immediately check space-availability in the rear car park. If there are spaces at the rear, you
can leave your vehicle at the front for a short time, but you must move your vehicle as soon as the delivery
vehicle has been moved. If the spaces get taken in the meantime – you must move your vehicle off site.

Non-adherence to these rules could impact on our lease and/or hasten 60+ staff having to park off site instead of
a few.
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Office Telephones

Adelaide has a sophisticated telephone system in place. Given the nature of our industry, all incoming and
outgoing call traffic on office phones is recorded. Recorded lines will be monitored regularly.

When answering external calls the following process should be followed to ensure that we are providing the best
possible level of service:

      Staff should state their name when answering external calls;
      At the end of a call Staff should always ensure that the client has had their query resolved and ensure
       that if a client has further questions they should know whom to contact;
      When Staff are out of the office or at meetings, phones should be ‘made busy’ or diverted (unless an
       arrangement is in place where other members of staff pick up such calls);

An unmonitored telephone has been made available for Staff to make necessary personal calls. This line will not
be reviewed as part of the routine call reviews for compliance. The phone is located at the bottom of the sales
office beside the public pc and the exit door to the admin office and may be used during official break-times.
Personal calls are therefore not to be made on the business lines during work. Personal calls received during
work time should be rare and kept short. If they are important, urgent and need to be longer, they should be
transferred to the unrecorded phone with prior authorisation from your line manager.

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Mobile Phone Usage

In the office, personal mobile phones should be switched off or to ‘silent’ during working hours as they can be
distracting for your colleagues and customers on the phone if they ring and are left unanswered. Personal calls
should not be made during your working hours. If you wish to make personal calls, you should restrict this to
breaks. Personal calls received during work time should be rare and be kept short, and should not interrupt your
service to customers of the Company. If special circumstances arise and you may need to be contacted urgently
for personal reasons during work, please seek prior authorisation to receive calls during work from your
manager.

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Part 6                           Recruitment and performance policy
                                             “Gather everyone (gather everyone)
                                           Gather all together (gather all together)
                                            Overlookin’ none (overlookin’ none)
                                            Hopin’ life gets better for the world”

                                           Harvest for the World – Isley Brothers

Equal Opportunity Policy – Fair Employment

Policy

To ensure promotion of the principle of equality of opportunity in employment the Company will:-

1. Ensure that all recruitment, training and promotion of staff are based on the principle of merit.

2. The Company will endeavour to keep under review the requirements of employees and applicants for
   employment who have or have had a disability in order to ensure that wherever possible reasonable
   adjustments may be made to enable them to remain in employment and perform the duties of their post, or to
   enter into employment with the Company. Every reasonable effort will be made that disabled staff participate
   fully in the workplace and are able to avail of promotion opportunities, benefits and facilities of employment.

3. Promote a good and harmonious working environment in which no employee feels under threat or
   intimidated because of their religious belief or political opinion and in which all employees are treated with
   dignity and employees do not feel apprehensive because of their gender. The Company will not condone
   harassment in the workplace and operates a policy on sexual, religious/political, racial and disability
   harassment.

4. Any employee who has concerns within the scope of this policy may raise any such allegations through the
   Company’s grievance procedure pr as provided for by the harassment policy as appropriate.

5. Any breach of this policy or the Company’s harassment policy will be viewed as gross misconduct and any
   employee found to be in such breach will be subject to disciplinary action up to and including summary
   dismissal.

6. The Company will take steps to bring this policy to the attention of every employee.

7. The Company will review the operation of this policy on a regular basis.
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Responsibilities

The Company Director is responsible for the overall effective implementation if the policy.

All supervisory and managerial staff has responsibility for promoting equality of opportunity and ensuring that this
policy is implemented.

Individual employees are expected to comply with this policy, to co-operate with measures introduced by the
Company to promote equality of opportunity and eliminate discrimination and to comply with the Company’s
harassment policy.
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Employment of Relatives

The Company is very pleased when current employees recommend their friends and family for positions
available within the Company. The Company continues to encourage employees to recommend these
individuals when we have employment opportunities within the Company.

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Guidelines

   Relatives, for the purpose of the policy are defined as mother, father, brother, sister, spouse, son, daughter,
    grandparents, step-parents, step-children, mother-in-law, father-in-law, brother-in-law, sister-in-law, son-in-
    law and daughter-in-law. These guidelines may also be applied to persons with whom an employee resides.

   For all new hires, rehires, transfers, and promotions, relatives can be considered for positions that do not
    result in both relatives reporting to the same manager.

   Because of the confidential nature of the information in the Human Resources and Payroll Departments,
    employees in these departments should not have relatives working in any area of the Company.

   The Company also reserves the right not to employ close relatives when one relative will evaluate or audit
    the work of another; or the work relationship may create a conflict of interest, the appearance of favouritism,
    or may raise an internal control or security issue. Any exception to this policy must be warranted by business
    conditions and have Human Resources/Managing Director approval.

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Other Relationships

Members of staff who have a relationship or form a relationship (other than a work-related one) with another
member of staff should ensure that the relationship does not create conflict of interest, the appearance of
favouritism, any concern regarding internal control, security, or work performance.
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Performance Reviews

Formal performance reviews are conducted once a year within the Company. During your probationary period,
review(s) will also take place during this period. Reviews provide an opportunity for a two-way discussion with
your manager and will cover your progress, achievement of objectives and performance since your last
appraisal. More importantly, the meeting is an opportunity for both you and your Manager to look ahead to build
on strengths, address weaknesses, utilise potential, agree new objectives and recognise training and
development needs for the coming year. The Company’s Performance Development Policy is detailed below.

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Purpose and scope of the Performance Development Policy

To establish a performance-based evaluation system for employees which provides for an objective, consistent
and uniform method of measuring employees’ on-the-job performance. This policy is applicable to all employees
within the Company, however it does not apply to temporary employees.
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Outline of Performance Development System

   Each employee’s performance shall be reviewed and evaluated on an annual basis. The employee’s
    immediate Manager / Dept Head shall be responsible for conducting the evaluation.

    The evaluation shall consist of two parts:

           o   An annual formal performance development review; and

           o   A regular informal review throughout the year which is intended to provide the employee with a
               progress report on his or her work performance, indicate areas needing improvement and
               recognise areas of effective performance.

   The primary objectives of performance evaluation are to:


2e0b0836-d8fa-49ea-84d4-feadf3a2f888.doc                                                           Page 88 of 138
            o   Assist managers in making systematic and objective evaluations of work performance, which can
                be especially useful in determining certain human resource decisions.

            o   Provide a basis for determining training needs of individual employees.

            o   Give employees a detailed evaluation of their performance and provide them with the information
                needed to assist them in improving or sustaining their performance.

    The evaluation shall be based on job performance and employee qualifications, which shall, in turn, be based
     upon each position’s job description and key result areas or work standards.

    The annual review and on-going evaluations should give the employee a clear picture of where he / she
     stands in terms of performance standards and provide an opportunity for the individual to express
     disagreement with any points made. Each employee should also be encouraged to seek and receive
     guidance in improving performance.

     Employees shall also have the right to review the written evaluation and make written comments concerning
     any aspect of the evaluation. An employee may appeal his / her evaluation by asking that it be reviewed by
     the next level of management. The outcome of such a review is the final decision regarding the employee’s
     performance rating.
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Procedures

Procedures relating to the Performance Development Policy are detailed in the following documents:

“Managers’ Performance Development Review Procedure”

“Administrative Staff Performance Development Review Procedure”

Forms Relating to this Policy

D1      Employee’s Performance Planning Worksheet

D2      Manager’s Performance Planning Worksheet

D3      Performance Development Review Document (Administrative or Manager)

D3b     Supplemental Factors for supervisory Staff Members

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Opportunities & Progression

The Company is committed to providing opportunities for career advancement wherever possible. Whilst always
seeking to appoint the most suitable candidate, the Company encourages internal promotions wherever
possible. Likewise the development of employees’ skills and experience through transfers to different areas of
the Company is also encouraged.

Internal vacancies are advertised and if you are interested, you should contact the relevant senior Manager for
an internal application form. An application does not constitute commitment on the part of the individual and it
can be withdrawn at any stage. Internal applications will not jeopardise the current position of the individual in
any way.
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Lay-Off / Short-Time

While it is the Company’s intention to provide continuity of employment, both parties recognise that there may be
circumstances outside the Company’s control which necessitate short-time working or lay-off.
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In order to delay and if possible to avoid such circumstances, employees must be prepared to accept reasonable
alternative work if their own work is not available.

Should the need arise to put staff on short-time or lay them off, the Company will give as much notice as is
reasonable in the circumstances.

Employees will be paid only for actual hours worked during such periods.

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Redundancy

It is recognised that circumstances may arise which leave the Company with no alternative but to declare
redundancies.

Where employees are made redundant the prime consideration will be to protect the employment of as many
people as possible, consistent with maintaining a fully efficient operation.

Should the need for redundancy arise, appropriate consultation will take place with representatives.

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Part 7                                        Other policies
                                             “I’m gonna get dressed for success
                                           shaping me up for the big time, baby.
                                                  Get dressed for success”

                                                         Roxette


Intellectual Property

During the course of your employment your duties may result in you making or participating in the making of new
and original inventions and implementing improvements by means of such inventions and the creation of plans
and documents or other intellectual property. The following Clauses set out the terms and conditions of your
employment in relation to such matters.

1. In these Clauses the expression ‘Intellectual Property’ shall mean:

   a) Every invention, discovery, development, process, formula, design, program or improvement (collectively
      referred to as ‘Inventions’);
   b) Every copyright work or design in which copyright or design rights may subsist and moral rights as
      defined by the Copyright, Designs and Patents Act 1988 (collectively referred to as ‘Works’)

2. If at any time, during your employment, you make or discover or participate with another or any others to
   make an Invention you must immediately disclose to the Company in confidence full details of any such
   Invention to allow the Company to determine the ownership of the Inventions in accordance with these
   Clauses and subject to the Patents Act 1977.

3. Inventions made or originated wholly or substantially in the course of your normal duties or in the course of
   duties falling outside your normal duties, but specifically assigned to you and the circumstances in either
   case were such that Inventions might reasonably be expected to result from your carrying out these duties,
   or in the course of your duties, at the time of making the Inventions, because of the nature of your duties you
   had a special obligation to further the interest of the Company’s undertaking the following sub-clauses of this
   Clause shall apply.

   a) Such inventions (or in the case of Inventions made or originated by you jointly with another or others to
      the full extent of your interest therein so far as the law allows) shall be held by you in trust for the
      Company and shall be subject to s39 of the Patents Act 1977 belong to and become the absolute
      property of the Company and shall not be disclosed to any other person, firm or company without the
      consent of the Company being previously obtained.
   b) The provisions of this Clause shall not entitle you to any compensation beyond your normal salary. The
      Company shall only be bound to provide you with additional reward in the case of any Inventions on
      which a British Patent has been granted or assigned to the Company and in respect of which the
      Company has derives outstanding benefit from such patent, in which case you may be entitled by virtue
      of s40 of the Patents Act 1977 to claim additional compensation. If no additional compensation is
      payable the Company may nevertheless at its absolute discretion award you an ex-gratia payment of
      compensation in recognition of your work.
   c) You shall if and when required by the Company and at the expense of the Company provide the
      Company with all such documents and information and such assistance and do and/or combine with
      others in doing all acts and sign and execute all applications and other documents (including Powers of
      Attorney in favour of nominees of the Company) necessary




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Communications

Good communication is essential for both management and staff. There are numerous methods of
communication within the Company including formal and informal meetings between managers and staff,
general subject emails or memoranda circulated throughout the company, staff briefings and notice boards.


Department Meetings
These meetings should be held at regular intervals by each department manager/head with all staff present.
The objectives of the meetings are to improve communication between staff and management at all levels and to
provide an opportunity for two-way discussion on any matter concerning the operation of the department. Each
member of staff is expected to prepare for these meetings and to contribute positively to them. By doing so, the
view of staff can be taken into account by the department manager.

Management Meetings
These meetings should be held each week between management. When these are in progress, other staff
should avoid disturbing the meetings unless the matter is urgent. Certain general queries should be referred to
other senior members of staff or left until the managers have finished the meeting. The meeting should be
interrupted where calls are received regarding staff members who are absent, or calls are received from Head
Office Directors.

Notice Boards
Notice boards are located at a central point and many general communications are made to staff by notices. It is
therefore important that staff regularly check the notice board to keep up to date with relevant issues. The notice
boards are primarily for the use of the Company, however, should staff wish to use the facility to post a general
communication to staff, they should seek approval from management prior to using the notice board.

Message taking
Where a message is required to be passed to another person, clear and adequate details must be taken.

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Dress Code

How a member of staff dresses is a statement about him/herself and about the Company as a whole. Whether
one is interacting with fellow employees on the job, meeting with customers or other business people, or
representing Adelaide Insurance Services Ltd at a meeting or conference, attire, behaviour, and attitude say a lot
about a person.

All staff are expected to dress in a businesslike manner and to maintain the standard of dress appropriate to a
financial services environment. Remember 3 words: businesslike, conservative, formal.

All staff will be requires to wear a tailored business suit.

   For female staff this will be:
       a collared front-buttoning blouse
       skirt / trousers
       matching jacket and if desired a waistcoat
       coordinating conservative shoes

   For male staff this will be:
       a collared front-buttoning shirt
       a tie (ties may not be required at all times – check with management)
       matching trousers
       matching jacket and if desired a waistcoat
       coordinating conservative shoes

Although suit jackets / waistcoats need not be worn at all times, on occasions where staff consider a blouse/ shirt
insufficient, suit jackets must be worn and no alternatives.
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Items not acceptable during work will therefore include:
     cardigans, jumpers, sweatshirts, ‘fleece’-jackets, blazers, sports-jackets,
     trainers, flip-flops,
     any denim or knitwear,
     T-shirts, polo-shirts,
     combat / cargo trousers,
     and other such casual clothes or footwear.

Jewellery will only be allowed where it is deemed appropriate to the aforementioned financial services
environment.

If you travel to work by bike and you do not find it suitable to wear a suit-jacket travelling to work, you should
have a suit jacket in work which you can wear as necessary.

If you do wear a casual jacket /coat /fleece /sweatshirt etc travelling to work, you are not to hang them over the
back of your chair in work – hang them in the cloakroom (at the wall beside the reception in the sales office). As
a leading motorcycle insurance provider, we will allow members of the motorcycle team to hang ‘motorcycle
jackets’ over the back of their chairs.
Otherwise, the main point of the Dress Code is to promote a smart businesslike image to customers and visitors.

Failure to adhere to the Dress Code requirements will lead to a penalty on your incentive (see Incentive terms).

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Secondary Employment

The Company requires the full commitment of staff members to their work. Staff members who engage in
secondary employment may not be able to give their full attention to the requirements of their position in the
company and this may result in reduction in the efficiency of their performance.

Consequently if you are contemplating secondary employment you must advise the company at the earliest
opportunity and seek approval in writing from the Company to undertake the secondary employment. Approval
for undertaking secondary employment will be given where the Company is satisfied that there will be no
adverse effect on the staff member’s performance in carrying out the company’s requirement. Serious or
repeated breaches of this clause may involve sanction under the Disciplinary Procedure.
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Business Expenses

From time to time, staff members may incur business expenses in the course of their work. Wherever possible,
approval to incur the expense should be obtained from the staff member’s Manager in advance. Staff members
have a responsibility to ensure that any expense incurred is kept to the minimum possible and that receipts are
obtained. Staff members will be reimbursed for approved expenses, provided that they are submitted together
with appropriate receipts within a month.
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Business Gifts

From time to time, staff members may be offered gifts from customers or suppliers. To protect staff members
from a conflict of interest, details of any gift received must be advised to the Departmental manager together
with, if known, the reason for the gift and the approximate value of the gift. At Christmas time, it is Company
policy that all gifts are pooled and will be shared by all staff in a manner decided by Senior Management.


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Speaking-Up Policy and Procedure

Introduction

Adelaide Insurance Services is committed to the highest standard of openness, integrity, accountability and
compliance.

Because of this, it is important to have a process, which allows all staff and other people who work with or for
Adelaide, to raise any concerns they may have about suspected wrongdoing within Adelaide. It is clearly in all
our interests to ensure that wrongdoing does not occur in any of our businesses, and in the unlikely event of it
occurring, that our people have a process to raise, investigate and address these issues within a reasonable
timeframe. It is also very important that anyone raising a concern in good faith can feel safe and confident that
Adelaide will treat the concern seriously, provide then adequate protection and ensure them fair treatment.

It is the duty of every staff member, irrespective of rank, to bring any concern they may have about suspected
wrong-doing to the attention of Adelaide’s management. The procedures attached to this policy set out the
practical steps in place to investigate these concerns in a systematic and timely way.

The Users’ Guide below sets out:
    the people covered by the policy
    our Speaking Up policy, (or “whistle blowing” policy, as it is sometimes called)
    the procedures to be followed by any staff in raising and investigating a concern, and
    the facilities and protection it offers people who, in good faith, look to get a full investigation carried out
      into some activity which they believe could constitute wrongdoing by Adelaide or its employees or agents.

It should be emphasised that this policy is intended to help individuals who believe they have discovered wrong
doing or impropriety. It is not designed to question financial or business decisions taken by the Company or
used to reconsider matters already addressed under harassment, complaint, disciplinary or other procedures.
The expectation is that staff will use this Speaking Up policy and procedure to prompt investigation by
Adelaide of suspected cases of wrongdoing within our business in the first instance, rather than air their
complaints outside Adelaide Insurance.

The protection given by this policy is based on staff adopting and following the procedures laid down. Staff
should only feel it necessary, in the public interest to refer their concerns to any external party where the internal
investigation falls below reasonable standards. In this unlikely case, a process for dealing with this is also set
out in this section.

The purpose of the policy is to encourage all staff to be vigilant and to feel confident they are supporting
Adelaide’s aims and fulfilling a key duty they have as a staff member in this important area by raising concerns,
about suspected wrongdoing, in good faith.

The procedures set out in the Users’ Guide to this policy are designed to encourage and protect any responsible
individual who needs to use the Speaking Up Policy.

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Users Guide

Adelaide has developed a Speaking Up policy and procedure to cover the raising of genuine concerns you
may have about suspected wrongdoing within Adelaide. (This is sometimes called a “Whistleblowing” Policy and
Procedure). This policy is aimed at offering you a way to raise your concerns in a supportive environment.

By providing this Speaking Up Policy and Procedure, and making sure that concerns raised under it are fully
investigated, Adelaide Insurance management expects you to use it to raise such concerns. This policy
assumes that if you have noticed wrongdoing, you will first use the policy and its procedures, and only refer your
concerns to an external party if you believe that any internal investigation falls below reasonable standards.
There is a process set out in this section for dealing with the unlikely situation where a person who has raised a
concern of wrongdoing is dissatisfied with the response or lack of response by Adelaide on the issue.

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The Speaking Up policy and its procedures attach to your contract of employment. It is the duty of each
member of staff to bring any concern they may have about suspected wrongdoing to the attention of Adelaide
management. This policy offers a practical way of doing this, and provides the process for investigating the
concerns involved.
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Policy

This Speaking up policy and procedures applies to staff. For the purposes of this Speaking Up Policy the
term “staff” includes all employees of Adelaide Insurance, including external consultants, contractors
and agency staff, working for or within Adelaide.

Wrongdoing includes, but is not confined to:
   Conduct likely to damage the reputation of Adelaide Insurance Services Ltd, or Cornmarket
     Group Financial Services Ltd, or Irish Life & Permanent Group
   Financial wrongdoing, dishonesty or fraud affecting Adelaide Insurance Services Ltd, or
     Cornmarket Group Financial Services Ltd, or Irish Life & Permanent Group, our customers or any
     other stakeholder
   Failure to comply with legal obligation, statutes and/or regulations
   Failure to comply with codes of conduct and/or practice
   Dangers to health and safety or the Environment
   Criminal Activity
   Improper conduct or unethical behaviour
   Breaches of internal rules
   Deliberate attempts to conceal any of the above or other cases of wrongdoing

A qualifying disclosure under the policy is one where the person making the disclosure reasonably believes that
one or more of the above has been committed, is being committed or is likely to be committed.

Adelaide Insurance management is committed to investigating fully any matters brought to its attention, under
the policy.

The policy protects you in making a disclosure within Adelaide where the disclosure covers one of the areas
above and is made in good faith.

In raising a wrongdoing concern, you can assume that only staff investigating the concern will know your identity.
If this is the case, we will notify you in advance and take all reasonable steps to make sure that you do not suffer
any difficulty as a result. Adelaide Insurance is also committed to acting in good faith with all matters connected
with this policy.

If you raise an instance of wrongdoing, you will be taken seriously and will be treated fairly and justly by
Adelaide. We will take all reasonable steps to make sure that no one under our control engages in victimisation
or other inappropriate behaviour towards you, or is allowed to interfere with the proper conduct of the
investigation.

Given the potentially sensitive nature of issues covered by this policy, and the serious consequences (in terms of
their reputation or career) for people about whom concerns of wrongdoing are raised, it is very important, that
those raising concerns of wrongdoing do so in good faith.

Disciplinary action will be taken against anyone found to have knowingly raised false or malicious concerns of
allegations of wrongdoing.

Equally, in raising a concern, you agree to co-operate fully with any investigation and to provide any information
you have which may be relevant to help investigate the matter.
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Pre Procedure

If you are unsure whether your concern is serious enough or suitable to be dealt with under this policy, you may
discuss it with your line manager, or any other member of Adelaide’s management team. Any of these will be
happy to help you to evaluate your concern and identify the approach you feel you want to use, if you decide it
should be pursued.

Policy

1. Raising a wrongdoing concern

   If you are a member of staff and have a wrongdoing concern, normally you should inform your immediate
   manager directly.

   1.1.      Ideally you should raise your concern with your line manager, in the first instance.

   1.2.      When you raise your concern in the first instance, it may be possible that your Manager may identify
             an action to be taken that will solve the problem or concern. In such cases the action to be taken and
             the time in which it is to be taken will be identified, and the decision will be left with you as to whether
             that action deals with your concern or you wish the concern to be processed through the Speaking Up
             Policy.

             If it is agreed that the proposed action deals with your concern, a note of your concern and the action
             taken will be logged by your Manager and retained by the Operations Manager. A copy of the logged
             note will be given to you.

   1.3.      Sometimes a concern raised under this policy may be more appropriate to another policy (e.g.
             Grievance Policy). If, following discussion with your line manager it is agreed that your concern is
             more properly handled under another policy, your line manager will log the fact that the concern was
             raised, and that it was agreed that another policy is more properly applied to the concern, and the note
             will be retained by the Operations Manager. You will be given a copy of the logged note.
             The matter can then be dealt with as per the policy that applies to it.

   1.4       If the examples above do not apply, your manager will then raise the matter under this policy with the
             Operations Manager to get the investigation process started as soon as possible.

   1.5       If, however, the concern involves your immediate manager or for any reason you would prefer them
             not to be told, you may raise the matter directly with the Operations Manager or Director.


2. Organising the Investigation of your Concern

   Adelaide will appoint an Investigating Officer to investigate your concerns, and to issue findings on the
   matter. The investigation process will generally have 3 stages:
      (i) fact find stage where we try to understand the issue you have the concern about,
      (ii) investigation stage,
      (iii) findings stage.
   It may be necessary in certain cases to refer the matters investigated to be dealt with under the disciplinary
   procedure. In these cases the disciplinary procedure will be a fourth step in the process.


   (i) Fact Find Stage – Clarifying and Understanding the Concern

          The Investigating Officer will meet with you to discuss the concern.

          The purpose of this stage is to make sure we understand the concern and for you to give as much details
          as you can to help the investigation process.

          The Investigating Officer appointed to investigate your concern may be joined by any member of
          Adelaide Staff or other specialists as may be needed to effectively investigate your concern.
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  (ii) Investigation Stage

       The Investigating Officer will conduct a full investigation to establish if wrongdoing has occurred. The
       format of the investigation may vary depending on the circumstances. The rights of the individuals who
       are under investigation shall be the same as those in any internal audit investigation. People, who are
       the subject to investigation arising from concerns raised under this policy, will also have the right to be
       accompanied by a work colleague or trade union official as per the normal investigative processes in
       Adelaide.

       You will be required to co-operate fully with the investigation.

       The complexity of the particular issue will affect the timeframe for the investigation, but the Investigating
       Officer will try to give you a sense of the likely timeframe involves for your own case.

  (iii) Findings Stage

       Except in cases where the preliminary findings are referred to the disciplinary procedure [see (iv)
       Disciplinary Procedure below] the Investigating Officer may communicate the findings of the investigation
       or a summary of them to:

          You as the person raising the wrongdoing concern
          The individual(s) under investigation
          Adelaide Insurance’s Director
          The Head of your Department
          Any member if Adelaide’s management team
          Following consultation with the company director, any other members of the Cornmarket Group Board
           of Directors, or external authorities who need to consider what action, if any, should be taken on the
           basis of the findings.

  (iv) Disciplinary Procedure

       If as a result of the preliminary findings of the investigation, the Company believes that disciplinary action
       may be taken, it will defer issuing the findings of the investigation or a summary of them until the
       disciplinary procedure has been completed.
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General

If you have disclosed your worry under this policy and are concerned whether by the response or lack of
response, you may contact the Company Director directly and request a review of the case.

In the unlikely event that you feel you cannot speak to anyone internally about a concern or about any
unreasonable delay by Adelaide Insurance in dealing with a concern you have already raised under this policy,
you can contact the Financial Services Authority, who regulate our business activities, giving then details of your
concern, and they will take up the matter for you.

Any queries relating to these procedures may be raised with your line manager, the Compliance Officer, or the
Head of your Department.

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Bribery

The Bribery Act 2010 came into effect in 2011 and covers the criminal law relating to bribery. The purpose of the
Act is to reform the criminal law of bribery to provide for a new consolidated scheme of bribery offences to cover
bribery both in the United Kingdom and abroad.

The Act repeals all previous statutory and common law provisions in relation to bribery, instead replacing them
with the crimes of bribery, being bribed, the bribery of foreign public officials, and the failure of a commercial
organisations to prevent bribery on its behalf.

Adelaide Insurance anti-bribery policy can be viewed in appendix 25.

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Car Use

Employees within Adelaide may from time to time need to use their own vehicle to attend work related events
etc. When this occurs it is essential that each vehicle is roadworthy and that each driver is not under the
influence of any type of alcohol or drugs when driving the vehicle. Adelaide has every right to check the drivers
licence for any accidents or convictions and their insurance documents to ensure they are legal for the road.

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Company Vehicle Use

Where the Company provides a pool vehicle for use by members of staff (who are named on the insurance
certificate) where the need arises and for a specific business purpose, the following policy applies to staff who
may use the vehicle.

The vehicle is a business tool and is provided in order that the Company’s business may be carried our more
effectively and efficiently. The Company reserves the right to:

      withdraw the vehicle at any time; or
      change the vehicle to any other make, model or year of vehicle; or
      vary the provisions of this vehicle Use policy at its discretion and at any time without prior notification.

In the case of accident or servicing, there will be no automatic provision of a replacement vehicle. Where a
replacement is essential for business use, the Company’s senior management must sanction in advance in
writing any hire arrangement.

All normal expenses in connection with the insurance, use, maintenance and repair of the vehicle and business
fuel costs will be paid by the company with the following exceptions:

      fines for motoring offences including parking / clamping
      legal and other costs not covered by the Company’s insurance
      car parking charges incurred in private motoring

The Company will reimburse the reasonable cost of basic maintenance of the vehicle. Valid receipts for this
basic maintenance must be presented in order to reclaim expenses. Employees should obtain prior written
consent of senior management in relation to work being carried out.

The company will arrange for the provision of the Road Fund Licence. If at the end of the licence year a new
Road Fund Licence has not been issued, the Company must be notified immediately. Under no circumstances
should the vehicle be driven without a current Road Fund Licence.
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Prohibited Uses

The vehicle must not be used for:

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      the carriage of goods or passengers for hire or reward
      giving driving tuition
      racing, competition, rallies or trials
      holidays
      trips abroad
      in connection with any business other than that of the Company

Failure to observe these conditions may result in disciplinary proceedings.
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Authorised drivers

The vehicle may only be driven by employees with the prior approval of management and who are named on the
insurance certificate or covernote.

Under no circumstances may spouses, partners, children, friends of employees or others be permitted to drive
the vehicle, without the prior authorisation of senior management and after adding them to the insurance.
Failure to observe these conditions may result in disciplinary proceedings.
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Driving Licence

The Company maintains the right at any time to require a member of staff using the company vehicle to produce
their driving licence/.

All penalty points accumulated by an employee, who uses the company vehicle, must be notified to the
Company immediately.

Where an employee, who uses a company vehicle, obtains a record of persistent driving offences or accidents,
following investigation the Company may withdraw use of the vehicle.

The Company is under no obligation to provide alternative transport to any member of staff, using the company
vehicle, who loses their licence and/or is disqualified from driving. Where this occurs and the employee relies
on the use of the vehicle for fulfilment of his/her duties/roles, the company reserves the right to
terminate their employment with or without notice.
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Material Facts and Information

All employees, who use the company vehicle, are required to disclose details of accident record or motoring
offences, including penalty points and any pending prosecutions. They must also disclose details of any
physical or mental infirmity which may impair their ability to drive.
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Penalties for Offences

The employee using the company vehicle is responsible for paying fines, legal charges or penalties imposed in
respect of their use of the vehicle. Fines, legal charges or penalties includes, but is not limited to:
    speeding
    parking tickets
    any other traffic violations.

Should an employee be charged with any offence and/or should they receive any fines, legal charges or
penalties, whether as a passenger or as a driver, he/she must report the matter immediately to the Company.

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Insurance

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All company vehicles are insured under a comprehensive Insurance Policy. A covernote or Certificate will be
supplied and the full policy is available for inspection from the Company.

The insurance for the personal effects carried in the vehicle in excess of the limit referred to in the policy remain
the responsibility of staff travelling in the vehicle. Staff should make adequate arrangements for the insurance of
private property carried in the vehicle. Staff members must take all reasonable precautions to secure the vehicle
while unattended, and the vehicle must be left in the most secure location as is reasonably possible. Any work-
related items such as presentation folders, stationery or literature should not be left in or on the vehicle when
unattended, as it may invalidate the insurance policy.

Where a breakdown recovery policy has been arranged on the company vehicle, the current certificate with the
recovery telephone number noted should be left in the glove-box of the company vehicle at all times.
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Windscreen Damage, Theft Claims and Damage

Replacement of windscreens should be agreed in advance by the company except in an emergency when they
should be fitted by an approved supplier.

Theft of the vehicle or any accessory from the vehicle should be notified to the Company without delay and
should also be reported to the policy (obtain a crime report number). A claim form should also be obtained and
completed giving full details of the circumstances (refer also re personal effects – above).

Any damage to the vehicle must be reported to the Company without delay. Any necessary consequent action
must be agreed with the Company in advance.
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Service Maintenance and Repairs

When the vehicle is serviced, the service book must be updated by the garage and the book must always remain
with the vehicle as its loss may jeopardise any warranty claim / resale value.

Vehicle users are expected to be responsible for the basic maintenance of the vehicle which means:

      keeping the vehicle clean and in good condition both inside and out and maintaining the vehicle to a high
       standard to ensure a pristine appearance
      keeping the vehicle in a roadworthy and legal condition by, for example,
           o checking tyres to ensure at more than legal minimum tread and correct pressure
           o lights, oil, fuel, radiator and windscreen washer levels and coolant levels as appropriate.

Vehicle users must drive in a safe, lawful and courteous manner at all times. They must ensure that all persons
travelling in the vehicle wear seatbelts. On no account should the vehicle be driven in a manner likely to result in
excessive engine, tyre or component wear or which jeopardises the insurance cover.

The user must inform the Company immediately should he/she consider that remedial action is necessary on the
vehicle either in order to carry out repairs or replace components.

Failure to comply with the above requirements could result in prosecution, or the Company’s insurers refusing to
provide indemnity in the event of an accident. In appropriate circumstances, disciplinary action may follow.

Any costs incurred in repairing the vehicle due to neglect may be recovered from staff that has used the vehicle,
if it is shown that they have neglected to take care of the vehicle.
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Expenses

In the rare occasion that motoring expenses are incurred whilst using the vehicle for private uses, such
expenses are the responsibility of the employee using the company vehicle at the time.


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All other expenses relating to fuel or expenses incurred while carrying out basic maintenance must be supported
by a valid receipt (and credit/debit card receipt where used).

Should the employment of a member of staff using the vehicle be terminated for whatever reason, they must
return the vehicle, all documentation relating to the vehicle, all keys and company equipment contained in the
vehicle, immediately to the Company’s office:

 Adelaide Insurance Services Ltd
 First Floor Boucher Plaza
 4-6 Boucher Road
 Belfast
 BT12 6HR

The vehicle must be returned upon leaving the Company or any date determined by the Company in a clean and
proper condition. The Company reserves the right to make a deduction from the employee’s wages or withdraw
any cash allowance to reflect the condition of the vehicle or the need for any repairs.

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Absences from work

It should be remembered at all times the company vehicle is a business tool and not a benefit of employment to
any staff member. Therefore, in the event that you commence maternity leave, or are absent for any other
reason including sickness and holidays, the vehicle must be returned immediately, or arrangements made for
return or collection of the vehicle.
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Appendices

Appendix 1 - Maternity notification

Note: This form must be submitted no later than the end of the 15th week before your expected week of
childbirth.

To                                    The Operations Manager, Adelaide Insurance Services Ltd
Name
Payroll/clock no
Dept/location

I wish to notify the Company that I am pregnant.

My expected date of
childbirth is
I intend my maternity leave
to begin on

I enclose my form MAT B1         *Yes/No *Delete as appropriate



Signed

Date




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Appendix 2 - Variation to maternity leave start date

Note: This form must be submitted at least 28 days before the proposed revised date for the start of your
maternity leave.

To                                The Operations Manager, Adelaide Insurance Services Ltd
Name
Payroll/clock no
Dept/location

I hereby notify the Company that I wish to change the start date for my maternity leave.

My previously notified start
date was
I now intend to start my
maternity leave on



Signed

Date




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Appendix 3 - Notification of early return from maternity leave

Note: This form must be submitted at least eight weeks before the date on which you intend to return to work
from maternity leave.

To                                The Operations Manager, Adelaide Insurance Services Ltd
Name
Payroll/clock no
Dept/location

I hereby notify the Company that I wish to return to work before the end of my additional maternity leave.

My date of return will be



Signed
Date




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Appendix 4 - Ordinary paternity leave self certificate (birth of child)


           Your dates for pay and leave
           The baby is due on:                                                    /        /

           And, if the baby has been born, please enter the actual                /        /
           date of birth:
           I would like my OPP and/or ordinary paternity leave to                 /        /
           start on
           I want to be away from work for:                               one/two weeks (delete as
                                                                          appropriate)
           Your declaration
           Surname:


           First names(s):



           National insurance number:

           You must be able to tick all three boxes below to get ordinary paternity pay and
           ordinary paternity leave.
           I declare that
              I am:
                  the baby’s biological father; or
                  married to the mother; or
                  living with the mother in an enduring family relationship, but am not
                   an immediate relative.
              I have responsibility for the child’s upbringing.


              I will take time off work to support the mother or care for the child.


           Signature:


           Date:                                                                  /        /

           Give this page to the Operations Manager, Adelaide Insurance Services Ltd.


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Appendix 5 - Ordinary paternity leave self certificate (UK adoption)

    Your dates for pay and leave
    The adoption agency told the person adopting the child                  /      /
    that they have been matched with a child on:
    The child is expected to be placed on:                                  /      /

    And, if the child has been placed, please enter the date                /      /
    they were placed:
    I would like my OPP and/or ordinary paternity leave to                  /      /
    start on:
    I want to be away from work for:                              one/two weeks (delete as
                                                                  appropriate)
    Your declaration
    Surname:
    First names(s):

    National insurance number:

    You must tick this box if you are adopting a child with your partner.
    I declare that I am adopting the child with my partner and I want to receive
    ordinary paternity pay and ordinary paternity leave not statutory adoption
    pay and adoption leave
    You must be able to tick all three boxes below to get ordinary paternity pay and
    ordinary paternity leave.
    I declare that
     I am:
         married to the person adopting the child; or
         living with the person adopting the child in an enduring family
            relationship, but am not an immediate relative; and


       I will have responsibility for the child’s upbringing.


       I will take time off work to support the person adopting the child or to
        care for the child.

    Signature:


    Date:                                                                   /      /

    Give this page to the Operations Manager, Adelaide Insurance Services Ltd.


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Appendix 6 - Ordinary paternity leave self certificate (overseas adoption)

Part 1 of 3
You must submit Part 1 of this form no later than 28 days after the child’s adopter receives official notification
from the relevant authority or, if the child’s adopter received official notification before you joined the company,
no later than 28 days after you have completed 26 weeks’ continuous service with the company.


     Surname:


     First names(s):



     National insurance number:

    Details of official notification
     The child’s adopter received official notification on:                  /       /

     The child is expected to enter the country on:                          /       /

     Your declaration
     You must tick this box if you are adopting a child with your partner.
     I declare that I am adopting the child with my partner and I want to receive
     ordinary paternity pay and ordinary paternity leave not statutory adoption
     pay and adoption leave
     You must be able to tick all three boxes below to get ordinary paternity pay and
     ordinary paternity leave.
     I declare that
        I am:
             married to the person adopting the child; or
             living with the person adopting the child in an enduring family
              relationship, but am not an immediate relative; and

        I will have responsibility for the child’s upbringing.


        I will take time off work to support the person adopting the child or to
         care for the child.

     Signature:


     Date:                                                                   /       /


Please retain Parts 2 and 3 of this form and submit them at the appropriate time

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Ordinary paternity leave self certificate (overseas adoption)


Part 2 of 3

You must submit Part 2 of this form at least 28 days before the date when you want your ordinary paternity leave
to start.

     Surname:


     First names(s):



     National insurance number:



    Notification of ordinary paternity leave
     I would like my OPP and/or ordinary paternity leave to             /        /
     start on:
     I want to be away from work for:                           one/two weeks (delete as
                                                                appropriate)



     Signature:


     Date:                                                              /        /




Please retain Part 3 of this form and submit it at the appropriate time
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Ordinary paternity leave self certificate (overseas adoption)
Part 3 of 3

You must submit Part 3 of this form within 28 days of the date when the child entered the country.

     Surname:


     First names(s):



     National insurance number:



    Notification of child’s date of entry
     The child in relation to whom I wish to take ordinary               /        /
     paternity leave entered the country on:


     Signature:


     Date:                                                               /        /


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Appendix 7 - Ordinary paternity leave - change of start date form


Note: This form must be submitted at least 28 days before the proposed revised date for the start of your
ordinary paternity leave.


        To                         The Operations Manager, Adelaide Insurance Services Ltd
        Name
        Payroll/clock no
        Dept/location

      I hereby notify the company that I wish to change the start date for my ordinary paternity leave.

        My previously notified
        start date was
        My previously notified
        period of ordinary         one/two weeks (Delete as appropriate)
        paternity leave was

        I now intend to start my
        ordinary paternity leave
        on
        My period of ordinary
                                   one/two weeks (Delete as appropriate)
        paternity leave will be


        Signed
        Date


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Appendix 8 - Additional paternity leave employee’s notice and declaration (birth)

You should complete and return this form at least eight weeks before the date on which you would like
your additional paternity leave and pay to start

Notice of intention to take additional paternity leave pay

          To                         The Operations Manager, Adelaide Insurance Services Ltd
          Name
          Payroll/clock no
          Dept/location

I hereby give notice of my intention to take additional paternity leave and receive additional paternity pay.

Please provide dates:

          The expected week of childbirth was
          The child’s actual date of birth was
          I would like my additional paternity leave to
          start on
          I would like my additional paternity leave to
          end on
          I expect the Company’s liability to pay
          additional paternity pay to begin on
          I expect the Company’s liability to pay
          additional paternity pay to end on


Declaration

I confirm that:

   I am the child’s biological father. [delete if inapplicable}

   I am not the child’s biological father, but I am the mother’s husband, partner or civil partner. [delete if
    inapplicable]

   I have or expect to have the main responsibility (apart from any responsibility of the child’s mother) for the
    upbringing of the child.

   The purpose of my additional paternity leave is to care for the child and I intend to care for the child during
    this period.

   The information I have provided is correct.

          Signed
          Date

Note: In addition to submitting this form, you also need submit a declaration completed by the mother of the
child.
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Appendix 9 - Additional paternity leave mother’s declaration (birth)

          To                         The Operations Manager, Adelaide Insurance Services Ltd
          Name of employee
          requesting additional
          paternity leave/pay
          Payroll/clock no
          Dept/location


The following sections should be completed by the child’s mother

          Name of child’s
          mother
          Address of child’s
          mother
          National insurance
          number of child’s
          mother

I hereby confirm that:

   I have given notice to my employer that I am returning to work after my maternity leave.

   I intend to return to work on (date) ……………….

   By reference to becoming pregnant, I became entitled to (delete as appropriate) statutory maternity
    pay/maternity allowance.

   My statutory maternity pay period, or maternity allowance period, began on (date)…………………..

   The employee named above is (delete as appropriate)

    My child’s biological father.

    Not my child’s biological father but is my husband, partner or civil partner.

   The employee named above has or expects to have the main responsibility (apart from my responsibility) for
    my child’s upbringing.

   To my knowledge, the employee named above is the only person taking additional paternity leave and
    claiming additional paternity pay in relation to my child.

   I consent to the employer of the person named above processing the information in this declaration.

          Signed (child’s mother)
          Date


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Appendix 10: Additional paternity leave employee’s notice and declaration (UK adoption)

You should complete and return this form at least eight weeks before the date on which you would like
your additional paternity leave and pay to start

Notice of intention to take additional paternity leave and pay

    To                        The Operations Manager, Adelaide Insurance Services Ltd
    Name
    Payroll/clock no
    Dept/location

I hereby give notice of my intention to take additional paternity leave and receive additional paternity pay.

Please provide dates:

    I was notified by the adoption agency of
    having been matched with a child on
    The child was actually placed for adoption
    on
    I would like my additional paternity leave to
    start on
    I would like my additional paternity leave to
    end on
    I expect the Company’s liability to pay
    additional paternity pay to begin on
    I expect the Company’s liability to pay
    additional paternity pay to end on


Declaration

I confirm that:

     I am married to, or the partner or civil partner of the child’s adopter.

     I have been matched with the child for adoption.

     The purpose of my additional paternity leave is to care for the child and I intend to care for the child during
      this period.

     The information I have provided is correct.


    Signed
    Date

Note: In addition to submitting this form, you also need submit a declaration completed by the adopter of the
child.
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Appendix 11 - Additional paternity leave adopter’s declaration (UK adoption)


    To                        The Operations Manager, Adelaide Insurance Services Ltd
    Name of employee
    requesting additional
    paternity leave/pay
    Payroll/clock no
    Dept/location


The following sections should be completed by the adopter who is taking adoption leave

    Name of adopter
    Address of adopter
    National Insurance
    Number of adopter

I hereby confirm that:

     I have given notice to my employer that I am returning to work after my adoption leave.

     I intend to return to work on (date) ……………….

     By reference to the adoption of a child, I became entitled to statutory adoption pay.

     My statutory adoption pay period began on (date)…………………..

     The employee named above is my spouse, partner or civil partner.

     To my knowledge, the employee named above is the only person taking additional paternity leave and
      claiming additional paternity pay in relation to the child.

     I consent to the employer of the person named above processing the information in this declaration.

    Signed (child’s mother)
    Date


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Appendix 12: Additional paternity leave employee’s notice/declaration (overseas adoption)

You should complete and return this form at least eight weeks before the date on which you would like
your additional paternity leave and pay to start

Notice of intention to take additional paternity leave and pay

    To                        The Operations Manager, Adelaide Insurance Services Ltd
    Name
    Payroll/clock no
    Dept/location

I hereby give notice of my intention to take additional paternity leave and receive additional paternity pay.

Please provide dates:

    The adopter received official notification
    from, or on behalf of, the relevant domestic
    authority on
    The child entered the country on
    I would like my additional paternity leave to
    start on
    I would like my additional paternity leave to
    end on
    I expect the Company’s liability to pay
    additional paternity pay to begin on
    I expect the Company’s liability to pay
    additional paternity pay to end on


Declaration

I confirm that:

     I am married to, or the partner or civil partner of the child’s adopter.

     I have or expect to have the main responsibility (apart from any responsibility of the adopter) for the child’s
      upbringing.

     The purpose of my additional paternity leave is to care for the child and I intend to care for the child during
      this period.

     The information I have provided is correct.


    Signed
    Date

Note: In addition to submitting this form, you also need submit a declaration completed by the adopter of the
child.
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Appendix 13: Additional paternity leave adopter’s declaration (overseas adoption)


          To                         The Operations Manager, Adelaide Insurance Services Ltd
          Name of employee
          requesting additional
          paternity leave/pay
          Payroll/clock no
          Dept/location


The following sections should be completed by the adopter who is taking adoption leave

          Name of adopter
          Address of adopter
          National Insurance
          Number of adopter

I hereby confirm that:

   I have given notice to my employer that I am returning to work after my adoption leave.

   I intend to return to work on (date) ……………….

   By reference to the adoption of a child, I became entitled to statutory adoption pay.

   My statutory adoption pay period began on (date)…………………..

   The employee named above is my spouse, partner or civil partner.

   To my knowledge, the employee named above is the only person taking additional paternity leave and
    claiming additional paternity pay in relation to the child.

   I consent to the employer of the person named above processing the information in this declaration.

          Signed (child’s mother)
          Date


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Appendix 14: Additional paternity leave - change of start date form


This form must be submitted at least six weeks in advance of the original start date for your additional paternity
leave or the new start date (whichever is the earlier)


        To                          The Operations Manager, Adelaide Insurance Services Ltd
        Name
        Payroll/clock no
        Dept/location

I hereby notify the company that I wish to change the start date for my additional paternity leave.

        My previously notified
        start date was
        My previously notified
        period of additional        From (give dates) [             ] to [               ]
        paternity leave was

        I now intend to start my
        additional paternity
        leave on
        My period of additional
                                    From (give dates) [               ] to [                 ]
        paternity leave will be


        Signed
        Date


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Appendix 15: Notification of early return from additional paternity leave


Note: This form must be submitted at least six weeks before the date on which you intend to return to work from
additional paternity leave.


         To                         The Operations Manager, Adelaide Insurance Services Ltd
         Name
         Payroll/clock no
         Dept/location

I hereby notify the company that I wish to return to work before the end of my additional paternity leave.

        My date of return will
        be


        Signed
        Date


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Appendix 16 - Form FW (A) Flexible Working Application Form


Note to the employee
You can use this form to make an application to work flexibly under the right provided in law to help
eligible employees care for their children. Before completing this form, you should first read the notes
in the section “Flexible Working”, and check that you are eligible to make a request.

You should note that under the right it may take up to 14 weeks to consider a request before it can be
implemented and possibly longer where difficulties arise. You should therefore ensure that you submit
your application to the appropriate person well in advance of the date you wish the request to take
effect.

It will help your employer to consider your request if you provide as much information as you can about
your desired working pattern. It is important that you complete all the questions as otherwise your
application may not be valid. When completing sections 3 & 4, think about what effect your change in
working pattern will have both on the work that you do and on your colleagues. Once you have
completed the form, you should immediately forward it to your employer (you might want to keep a
copy for your own records). Your employer will then have 28 days after the day your application is
received in which to arrange a meeting with you to discuss your request. If the request is granted, this
will be a permanent change to your terms and conditions unless otherwise agreed.



Note to the employer

This is a formal application made under the legal right to apply for flexible working and the duty on
employers to consider applications seriously. You have 28 days after the day you received this
application in which to either agree to the request or arrange a meeting with your employee to discuss
their request. You should confirm receipt of this application using the attached confirmation slip.

Forms accompanying the guidance have been provided for you to respond to this application.



1. Personal Details

Name:                                                  Staff or payroll number:


Manager:                                               National Insurance No:


To the employer

I would like to apply to work a flexible working pattern that is different to my current working pattern
under my right provided in law. I confirm I meet each of the eligibility criteria as follows:

• I have responsibility for the upbringing of either a child under 17 or a disabled child under 18.
• I am:
  - the mother, father, adopter, guardian or foster parent of the child; or
  - married to or the partner of the child’s mother, father, adopter, guardian or foster parent
• I am making this request to help me care for the child.
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• I am making this request no later than two weeks before the child’s 16th birthday or 18th birthday
  where disabled.
• I have worked continuously as an employee of the company for the last 26 weeks.
• I have not made a request to work flexibly under this right during the past 12 months.

If you do not meet any of the above criteria, then you do not qualify to make a request to work flexibly in
law. This does not mean that your request may not be considered, but you will have to explore this
separately with your employer.


2a. Describe your current working pattern (days /hours /times worked):




2b. Describe the working pattern you would like to work in future (days /hours /times worked):




(you may continue on a separate sheet if necessary)
2c. I would like this working pattern to commence from                Date:



3. Impact of the new working pattern
I think this change in my working pattern will affect my employer and colleagues as follows:




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4. Accommodating the new working pattern

I think the effect on my employer and colleagues can be dealt with as follows:




Name:                                                                           Date:


NOW PASS THIS APPLICATION TO YOUR EMPLOYER.




Employer: Cut this slip off and return it to your employee in order to confirm your receipt of their application

Employer’s Confirmation of Receipt (to be completed and returned to employee)


Dear:
I confirm that I received your request to change your work pattern on:          Date:

I shall be arranging a meeting to discuss your application within 28 days following this date. In the
meantime you might want to consider whether you would like a fellow colleague to accompany you at the
meeting.

From:




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Appendix 17 - Form FW (B) Flexible Working Application Acceptance Form

Note to the employer

You must write to your employee within 14 days following the meeting with your decision. This form
can be completed by the employer when accepting an application to work flexibly. If you cannot
accommodate the requested working pattern you may still wish to explore alternatives to find a working
pattern suitable to both parties.
Please note that Form C: Flexible Working Application Rejection Form should be used if the
employee’s working pattern cannot be changed, and no other suitable alternatives can be found.




Dear:                                                                   Staff No:

Following receipt of your application and our meeting on:
                                                                        Date:
I have considered your request for a new flexible working pattern.
I am pleased to confirm that I am able to accommodate your application.
I am unable to accommodate your original request. However, I am able to offer the alternative pattern
which we have discussed and you agreed would be suitable to you.
Our new working pattern will be as follows:




Your new working arrangements will begin from:                          Date:


Note to the employee

Please note that the change in your working pattern will be a permanent change to your terms and
conditions of employment and you have no right in law to revert back to your previous working pattern.


If you have any questions on the information provided on this form please contact me to discuss them
as soon as possible.


Name :                                                                  Date:



NOW RETURN THIS FORM TO YOUR EMPLOYEE
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Appendix 18 - Form FW(C) Flexible Working Application Rejection Form

Note to the employer

You must write to your employee within 14 days following the meeting with your decision. This form
can be completed by you when declining an application. Before completing this form you must ensure
that full consideration has been given to the application. You must state the business ground(s) as to
why you are unable to agree to a new working pattern and the reasons why the ground(s) applies in the
circumstances


Dear:                                                                 Staff No:


Following receipt of your application and our meeting on:             Date:
I have considered your request for a new flexible working pattern.
I am sorry but I am unable to accommodate your request for the following business ground(s):




The grounds apply in the circumstances because:




(You should explain why any other work patters you may have discussed at the meeting are also
inappropriate. Please continue on a blank sheet if necessary).




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If you are unhappy with the decision you may appeal against it. Details of the appeal procedure are set
out below.

Name:                                                                  Date:


The Appeal Process

To the employee

If your employer turns down your request for flexible working, you have the right to appeal against the
decision. If you wish to appeal, you must write to your employer, setting out the grounds for your
appeal, within 14 days after receiving written notice of his decision.

To the employer

If you reject your employee’s request for flexible working, your employee has the right to appeal against
our decision.

If your employee appeals against your decision to refuse a request for flexible working, you must
arrange a meeting with your employee to discuss the appeal within 14 days after receiving the appeal
letter.

After the meeting has been held, you must write to your employee within 14 days to notify him of the
outcome of the appeal.


NOW RETURN THIS FORM TO YOUR EMPLOYEE.




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Appendix 19 - Form FW (D) Flexible Working Appeal Form


Note to the employee

If your application has been refused, you may appeal against your employer’s decision. You can use
this form to make your appeal. You should set out the grounds on which you are appealing, and do so
within 14 days of receiving written notice that your application for flexible working has been turned
down.


Note to the employer

This is a formal appeal made under the legal right to apply for flexible working. You have 14 days
following our receipt of this form in which to arrange a meeting with your employee to discuss their
appeal.

Form FW (E) Flexible Working Appeal Reply Form, to use when responding to this appeal, has been
provided.




Dear:

I wish to appeal against your decision to refuse my application for flexible working. I am appealing on
the following grounds:




(Please continue on a blank sheet if necessary)

Name:                                                                   Date:



NOW RETURN THIS FORM TO YOUR EMPLOYER



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Appendix 20 - Form FW (E) Flexible Working Appeal Reply Form


Note to the employer

You may complete this form when replying to an appeal that an application to work flexibly has not
been properly considered. You must return this form to your employee, giving notice of your decision,
within 14 days after the meeting at which you both discussed the appeal. If you decide to turn down
the appeal, you must state the grounds for your refusal.



Dear:                                                                  Staff No:

Following our meeting on:
I have considered your appeal against the decision to refuse your      Date:
application to work flexible working pattern.
I accept your appeal against the decision. I am therefore able to accommodate your original request to
change your working pattern as follows:




Your new working arrangements will begin from:                         Date:

Note to the employee

Please note that the change in your working pattern will be a permanent change to your terms and
conditions of employment and you have no right in law to revert back to your previous working pattern.

I am sorry but I must reject your appeal on the following ground(s):




The ground(s) apply because:




(please continue on a separate sheet if necessary).

Name:                                                                  Date:


NOW RETURN THIS FORM TO YOUR EMPLOYEE.


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Appendix 21 - Form FW (F) Flexible Working Extension of Time Limit

Note to the employer

This form is provided for you to complete when confirming agreement with your employee that you wish
to extend a time limit for part of the procedure, from that set out in the regulations. You may extend the
time limit for any part of the process, providing your employee agrees to the extension.



Dear:                                                               Staff No:

I wish to extend the amount of time that the regulations allow me to:
 Arrange a meeting to discuss your application (28 days)
 Notify you of my decision regarding your application (14 days)
 Arrange a meeting to discuss your appeal (14 days)
 Notify you of my decision regarding (14 days)
I wish to extend the time limit to days. This means that I will have until:
to complete the necessary action. I need the extra time for the following reason:




If you agree to this extension, please complete the slip below and return it to me.

Signed:                                                                              Date:


NOW PASS THIS APPLICATION TO YOUR EMPLOYEE.

Note to the employee

To allow proper consideration of your request, your employer may wish to extend the permitted time
limit for any part of the process. Your employer will need your agreement to any extension of the time
limit. If you agree to the above request, please complete the agreement slip below and return it to your
employer.


Cut this slip off and return it to your employer in order to confirm your acceptance of their request

Employee’s Agreement to Time Extension (to be completed and returned to employer)
Dear:
I accept your request to extend the amount of time to:
Signed:                                                                         Date:


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Appendix 22 - FW (G) Flexible Working Notice of Withdrawal Form


Note to the employee

This form provides notification to your employer that you wish to withdraw your application to work
flexibly. Once you have withdrawn your application, you will not be able to make another application
until 12 months from the date your original application was made.



Dear:

I wish to withdraw my application to work flexibly which I submitted
to you on:
I understand that I will not be able to make another application until twelve months after the above date.

Name:                                                                            Date:


NOW RETURN THIS FORM TO YOUR EMPLOYER.

Note to the employer

Once your employee has completed this form and returned it to you, the application is considered as
withdrawn and you are not required to give it any further consideration.

You should complete the slip below and return it to your employee to confirm your receipt of the
withdrawal notice.


Cut this slip off and return it to your employee in order to confirm your receipt of their withdrawal notice.




Employer’s Confirmation of Withdrawal (to be completed and returned to employee)

Dear:

I confirm that I have received notice that you wish to withdraw your
                                                                           Date
application for flexible working which you submitted to me on:
Under the right to apply, you will not be eligible to submit another application until twelve months after
the above date.

From:                                                                            Date:




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Appendix 23 - Notice to Employer of Force Majeure Leave

This form must be completed by an employee who takes force majeure leave as soon as reasonably practicable
after the leave is taken. An employee is entitled to force majeure leave where for urgent family reasons, owing to
an injury to or the illness of a person referred to in section 13(2) of the Act, the employee's immediate presence
is indispensable at the place where the person is. The persons referred to in section 13(2) of the Act are: child,
adopted child or a person in relation to whom the employee is in loco parentis; spouse or person with whom the
employee is living as husband or wife; brother or sister; parent or grandparent.
Force majeure leave must not exceed 3 working days in any period of 12 consecutive months or 5 working days
in any period of 36 consecutive months.


Name of employee                              _________________________________


National Insurance Number


Name and address of employer




Name and address of
injured*/ill*person during
force majeure leave


Relationship to employee


Nature of injury*/illness*


Date(s) of force majeure leave


Declaration: I confirm that I have taken force majeure leave on the above-mentioned dates because for urgent
family reasons, owing to the injury to*/illness of* the person specified above, my immediate presence at that
person's address was indispensable.


Signature of employee:                                                     Date: ___/___/___


Human Resources:                                                           Date: ___/___/___


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Appendix 24 - Internal Job Application Form




Name:                                                                             Date: _ _ / _ __/ _ __
Position Applying For:
Current Position:
Length of Time in Current Position:
Manager:


I feel I have the necessary experience and qualifications for the above position, for the following
reasons:




What are the Key Achievements you can bring to the Job?




Briefly outline your Educational Details:




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Brief History of your Career to Date:




List Specific Relevant Training:




Other Relevant Information pertaining to your application:




Give Details of Outside Activities and Pastimes:




Signed:                                                Date: _ _ / _ __/ _   _

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Appendix 25 – Adelaide Insurances Bribery Policy

1.       Policy statement

1.1      It is our policy 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 and implementing and enforcing
         effective systems to counter bribery.

1.2      We will uphold all laws relevant to countering bribery and corruption [in all the jurisdictions in which we
         operate]. However, we remain bound by the laws of the UK, including the Bribery Act 2010, in respect of
         our conduct both at home and abroad.

1.3      The purpose of this policy is to:
         (a)   set out our responsibilities, and of those working for us, in observing and upholding our position on
               bribery and corruption; and
         (b)   provide information and guidance to those working for us on how to recognise and deal with bribery
               and corruption issues.

1.4      Bribery and corruption are punishable for individuals by up to ten years' imprisonment and if we are found
         to have taken part in corruption we could face an unlimited fine, be excluded from tendering for public
         contracts and face damage to our reputation. We therefore take our legal responsibilities very seriously.

1.5      We have identified that the following are particular risks for our business:

          Insurance companies offering the firm or employees ‘incentives’ for us to arrange certain business
           with them. This could contravene our requirements to offer the best policy to meet as many of the
           customers ‘demands and needs’ as possible.

          Firms could award brokers large bonuses directly related to the income or profit they generated. This
           could encourage risk-taking and negligence, and increase the risk of bribery and corruption,
           particularly where brokers use third parties to win business.

         To address those risks we carry out the following:

          Adelaide has daily and weekly spot checks which include checks which ensure that the most suitable
           policy has been sold to the customer to meet their demand and needs.

          Adelaide carry out regular telephone reviews to monitor and assess the competence of the sales staff
           which would also reveal any unethical conduct.

          Adelaide compile a weekly Complaints summary to identify any systemic or reoccurring trends and
           this is circulated to management.

          Adelaide request Customer Feedback from several hundred customers each month. Questions
           included are aimed to ascertain that we Treat Customers Fairly (TCF), eg if our product met the
           client’s needs and information given was clear and our service was appropriate, fair and not
           misleading; and comments are requested from the customers. Replies are collated. Adverse
           comments re service or product are dealt with by management. Part of monthly incentive payable for
           all sales advisors, admin and accounts staff is made up from Customer Feedback scores.
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          Aside from TCF-based incentives, sales advisors, admin and accounts staff can receive monthly
           incentives. Staff are paid annual salary which is not dependant on achievement of targets. The
           target-based incentives make up a small proportion of their annual remuneration to minimise risks of
           conflict of interest.

          Monthly targets set for individual sales advisors are based on achieving unit sales targets, not on
           income or company profit, in order to avoid encouraging staff from selling products which pay higher
           commissions.

          No targets are set for optional extras in order to avoid selling extras to customers who do not require
           them.

          If targets are not met, while incentive is not paid, staff are not penalised in other ways.

          Adelaide has an ‘Inducements Log’ in force to keep a record of inducements received and
           inducements given by Adelaide.

1.6      In this policy, third party means any individual or organisation you come into contact with during the
         course of your work for us, and includes actual and potential clients, customers, suppliers, distributors,
         business contacts, agents, advisers, and government and public bodies, including their advisors,
         representatives and officials, politicians and political parties.
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2.       Who is covered by the policy?

         This policy applies to all individuals working at all levels and grades, including senior managers, officers,
         directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees,
         seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or
         any other person associated with us, or any of our subsidiaries or their employees, wherever located
         (collectively referred to as workers in this policy).
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3.       What is bribery?

         A bribe is an inducement or reward offered, promised or provided in order to gain any commercial,
         contractual, regulatory or personal advantage.

               Examples:
               Offering a bribe
               You offer a potential client tickets to a major sporting event, but only if they agree
               to do business with us.
               This would be an offence as you are making the offer to gain a commercial and
               contractual advantage. We may also be found to have committed an offence
               because the offer has been made to obtain business for us. It may also be an
               offence for the potential client to accept your offer.
               Receiving a bribe
               A supplier gives your nephew a job, but makes it clear that in return they expect
               you to use your influence in our organisation to ensure we continue to do business

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               with them.
               It is an offence for a supplier to make such an offer. It would be an offence for you
               to accept the offer as you would be doing so to gain a personal advantage.
               Bribing a foreign official
               You arrange for the business to pay an additional payment to a foreign official to
               speed up an administrative process [such as clearing our goods through customs].
               The offence of bribing a foreign public official has been committed as soon as the
               offer is made. This is because it is made to gain a business advantage for us. We
               may also be found to have committed an offence.
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4.       Gifts and hospitality

4.1      This policy does not prohibit normal and appropriate hospitality (given and received) to or from third
         parties.

4.2      You are prohibited from [accepting a gift from or] giving a gift to a third party OR The giving [or receipt] of
         gifts is not prohibited, if the following requirements are met:
         (a)   it is not made with the intention of influencing a third party to obtain or retain business or a business
               advantage, or to reward the provision or retention of business or a business advantage, or in
               explicit or implicit exchange for favours or benefits;
         (b)   it complies with local law;
         (c)   it is given in our name, not in your name;
         (d)   it does not include cash or a cash equivalent (such as gift certificates or vouchers);
         (e)   it is appropriate in the circumstances. For example, in the UK it is customary for small gifts to be
               given at Christmas time;
         (f)   taking into account the reason for the gift, it is of an appropriate type and value and given at an
               appropriate time;
         (g)   it is given openly, not secretly; and
         (h)   gifts should not be offered to, or accepted from, government officials or representatives, or
               politicians or political parties, without the prior approval of our Compliance Manager (Lee-Ann
               Calwell) or in her absence our Operations Manager (David McKendry).

4.3      We appreciate that the practice of giving business gifts varies between countries and regions and what
         may be normal and acceptable in one region may not be in another. The test to be applied is whether in
         all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift
         should always be considered.
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5.       What is not acceptable?

         It is not acceptable for you (or someone on your behalf) to:
         (a)   give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a
               business advantage will be received, or to reward a business advantage already given;


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         (b)   give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or
               representative to "facilitate" or expedite a routine procedure;
         (c)   accept payment from a third party that you know or suspect is offered with the expectation that it will
               obtain a business advantage for them;
         (d)   accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with
               an expectation that a business advantage will be provided by us in return;
         (e)   threaten or retaliate against another worker who has refused to commit a bribery offence or who
               has raised concerns under this policy; or
         (f)   engage in any activity that might lead to a breach of this policy.

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6.       Facilitation payments and kickbacks

6.1      We do not make, and will not accept, facilitation payments or "kickbacks" of any kind. Facilitation
         payments are typically small, unofficial payments made to secure or expedite a routine government
         action by a government official. They are not commonly paid in the UK, but are common in some other
         jurisdictions.

6.2      If you are asked to make a payment on our behalf, you should always be mindful of what the payment is
         for and whether the amount requested is proportionate to the goods or services provided. You should
         always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns
         or queries regarding a payment, you should raise these with our Compliance Manager (Lee-Ann Calwell)
         or in her absence David McKendry (Operations Manager).

6.3      Kickbacks are typically payments made in return for a business favour or advantage. All workers must
         avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or
         accepted by us.
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7.       Donations

         We do not make contributions to political parties.

         We 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 our Director (Sam Geddis).
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8.       Your responsibilities

8.1      You must ensure that you read, understand and comply with this policy.

8.2      The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of
         all those working for us or under our control. All workers are required to avoid any activity that might lead
         to, or suggest, a breach of this policy.

8.3      You must notify your Manager OR the Compliance Manager as soon as possible if you believe or suspect
         that a conflict with this policy has occurred, or may occur in the future. For example, if a client or
         potential client offers you something to gain a business advantage with us, or indicates to you that a gift
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         or payment is required to secure their business. Further "red flags" that may indicate bribery or corruption
         are set out in the Schedule below.

8.4      Any employee who breaches this policy will face disciplinary procedure, which could result in dismissal
         for gross misconduct. [We reserve our right to terminate our contractual relationship with other workers if
         they breach this policy.]
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9.       Record-keeping

9.1      We must keep financial records and have appropriate internal controls in place which will evidence the
         business reason for making payments to third parties.

9.2      You must declare and keep a written record of all hospitality or gifts accepted or offered, which will be
         subject to managerial review.

9.3      You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are
         submitted in accordance with our expenses policy and specifically record the reason for the expenditure.

9.4      All accounts, invoices, memoranda and other documents and records relating to dealings with third
         parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict
         accuracy and completeness. No accounts must be kept "off-book" to facilitate or conceal improper
         payments.
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10.      How to raise a concern

         You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible
         stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other
         queries, these should be raised with your line manager OR the Compliance Manager. Concerns should
         be reported by following the procedure set out in our ‘Whistle-blowing’/Speaking-Up Policy which all
         employees receive with their contract of employment. A copy of our Whistle-blowing Policy can be found
         at: Z:\HR -PERSONNEL\Employment\H.R. misc\Speaking Up Policy –Nov05 or in our Employee
         Handbook.
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11.      What to do if you are a victim of bribery or corruption

         It is important that you tell our Compliance Manager (Lee-Ann Calwell) or in her absence our Operations
         Manager (David McKendry) as soon as possible if you are offered a bribe by a third party, are asked to
         make one, suspect that this may happen in the future, or believe that you are a victim of another form of
         unlawful activity.
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12.      Protection

12.1     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, even if they turn out to
         be mistaken.

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12.2   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 their suspicion that an actual or
       potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental
       treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with
       raising a concern. If you believe that you have suffered any such treatment, you should inform your
       manager or the Compliance Manager immediately. If the matter is not remedied, and you are an
       employee, you should raise it formally using our Grievance Procedure, which can be found in the staff
       handbook Z:\GENERAL REFERENCE\Staff folders\Adelaide Employee Handbook.
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13.    Training and communication

13.1   Training on this policy forms part of the induction process for all new workers. All existing workers will
       receive regular, relevant training on how to implement and adhere to this policy.

13.2   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 and as appropriate
       thereafter.
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14.    Who is responsible for the policy?

14.1   The board of directors has overall responsibility for ensuring this policy complies with our legal and
       ethical obligations, and that all those under our control comply with it.

14.2   The Compliance Manager has primary and day-to-day responsibility for implementing this policy, and for
       monitoring its use and effectiveness [and dealing with any queries on its interpretation]. Management at
       all levels are responsible for ensuring those reporting to them are made aware of and understand this
       policy and are given adequate and regular training on it.
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15.    Monitoring and review

15.1   The Compliance Manager will monitor the effectiveness and review the implementation of this policy,
       regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be
       made as soon as possible. Internal control systems and procedures will be subject to regular audits to
       provide assurance that they are effective in countering bribery and corruption.

15.2   All workers are responsible for the success of this policy and should ensure they use it to disclose any
       suspected danger or wrongdoing.

15.3   Workers are invited to comment on this policy and suggest ways in which it might be improved.
       Comments, suggestions and queries should be addressed to the Compliance Manager.

15.4   This policy does not form part of any employee's contract of employment and it may be amended at any
       time.
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                             Schedule      Potential risk scenarios: "red flags"


    The following is a list of possible red flags that may arise during the course of you working for us and
    which may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to
    be exhaustive and is for illustrative purposes only.

    If you encounter any of these red flags while working for us, you must report them promptly to the
    Compliance Manager, Lee-Ann Calwell or in her absence the Operations Manager, David McKendry OR
    by using the procedure set out in the Whistle-blowing /Speaking-Up Policy:
      (a)   you become aware that a third party engages in, or has been accused of engaging in, improper
            business practices;
      (b)   you learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to
            them, or has a reputation for having a "special relationship" with foreign government officials;
      (c)   a third party insists on receiving a commission or fee payment before committing to sign up to a
            contract with us, or carrying out a government function or process for us;
      (d)   a third party requests payment in cash and/or refuses to sign a formal commission or fee
            agreement, or to provide an invoice or receipt for a payment made;
      (e)   a third party requests that payment is made to a country or geographic location different from
            where the third party resides or conducts business;
      (f)   a third party requests an unexpected additional fee or commission to "facilitate" a service;
      (g)   a third party demands lavish entertainment or gifts before commencing or continuing contractual
            negotiations or provision of services;
      (h)   a third party requests that a payment is made to "overlook" potential legal violations;
      (i)   a third party requests that you provide employment or some other advantage to a friend or
            relative;
      (j)   you receive an invoice from a third party that appears to be non-standard or customised;
      (k)   a third party insists on the use of side letters or refuses to put terms agreed in writing;
      (l)   you notice that we have been invoiced for a commission or fee payment that appears large given
            the service stated to have been provided;
      (m) a third party requests or requires the use of an agent, intermediary, consultant, distributor or
          supplier that is not typically used by or known to us;
      (n)   you are offered an unusually generous gift or offered lavish hospitality by a third party.

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