Equality, Diversity and Inclusion Policy
Our Commitment
Thomas Howse Ltd is dedicated to promoting equality, diversity, and inclusion within our workforce while actively eliminating unlawful discrimination. We aim for our workforce to reflect the diversity of society and our customer base, ensuring that every employee feels respected, valued, and empowered to perform at their best.
We are equally committed to upholding these principles in the provision of goods, services, and facilities, opposing unlawful discrimination against customers, suppliers, and the public.
Purpose of the Policy
This policy aims to:
- Ensure equality, fairness, and respect for all employees, regardless of their employment status (temporary, part-time, or full-time).
- Prohibit unlawful discrimination as defined by the Equality Act 2010, including discrimination based on age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.
- Prevent all forms of unlawful discrimination in pay, benefits, employment terms, grievances, discipline, dismissal, redundancy, parental leave, flexible working requests, and decisions related to employment, promotion, training, or development opportunities.
Our Commitments
- Encourage Equality, Diversity, and Inclusion: We foster a culture where equality, diversity, and inclusion are embedded as good practice and sound business principles.
- Promote a Respectful Workplace: We strive to create an environment free of bullying, harassment, victimisation, and unlawful discrimination. Our workplace values dignity and respect for all, acknowledging the unique contributions of every employee.
- Managers and employees are trained to understand their rights and responsibilities under this policy.
- All staff are expected to contribute to a culture of equal opportunities and to actively prevent bullying, harassment, victimisation, and unlawful discrimination.
- Address Complaints Seriously:
- All complaints of bullying, harassment, victimisation, or unlawful discrimination by employees, customers, suppliers, or the public will be taken seriously and addressed promptly.
- Such incidents will be handled as misconduct under our grievance and disciplinary procedures. Severe cases may lead to dismissal for gross misconduct.
- Sexual harassment and related complaints may constitute employment rights violations and, in some cases, criminal offences under the Protection from Harassment Act 1997.
- Provide Equal Opportunities for Development:
- Training, development, and career progression opportunities are accessible to all employees.
- Employees are supported in realising their full potential, allowing their talents to benefit the organisation.
- Decisions are made on merit, with exceptions only where legally justified under the Equality Act.
- Maintain Fair Employment Practices:
- We regularly review employment practices and procedures to ensure compliance with this policy and relevant laws.
- The policy is updated to reflect legal and societal changes.
- Monitor and Improve:
- We assess workforce demographics, including age, sex, ethnicity, sexual orientation, religion, and disability, to promote equality, diversity, and inclusion.
- The policy and supporting actions are reviewed annually to ensure effectiveness, with necessary adjustments made to address identified issues.
Policy Support and Implementation
This policy is fully supported by senior management and, where appropriate, has been agreed upon with employee representatives.
Grievance and Disciplinary Procedures
Detailed grievance and disciplinary procedures, including how to raise concerns, are available in the Finance and Administration Office. Employees retain the right to file a claim with an employment tribunal within three months of alleged discrimination, independent of internal procedures.
Thomas Howse Ltd is committed to maintaining a workplace where equality, diversity, and inclusion thrive, benefiting both our employees and the broader community.
Ethical Trading Policy Incorporating Suppliers Activities
Introduction
This statement outlines the core principles of ethical trading that all suppliers and subcontractors to Thomas Howse Ltd must adhere to in order to uphold high standards of integrity and professionalism in their working practices.
Our policy is based on the Ethical Trading Initiative (ETI) Base Code, which is rooted in the conventions of the International Labour Organisation (ILO) and is an internationally recognised code of labour practice. However, it excludes Clause 10 – Safeguarding within the supply chain. By supplying goods or services under our terms and conditions, suppliers and subcontractors agree to uphold the following principles, which define our Ethical Trading Policy:
Core Ethical Principles
- Employment is Freely Chosen
1.1 There must be no forced, bonded, or involuntary prison labour.
1.2 Workers must not be required to lodge “deposits” or their identity papers with their employer and must be free to leave their employment after providing reasonable notice.
- Freedom of Association and Collective Bargaining
2.1 Workers have the right to join or form trade unions of their choosing and to bargain collectively.
2.2 Employers must adopt an open attitude toward trade union activities and employee representatives.
2.3 Worker representatives must not face discrimination and must have access to perform their representative duties.
2.4 Where local law restricts freedom of association and collective bargaining, employers must facilitate parallel mechanisms for independent and free association and bargaining.
- Safe and Hygienic Working Conditions
3.1 A safe and hygienic working environment must be provided, addressing industry-specific hazards to prevent accidents and health risks.
3.2 Workers must receive regular, documented health and safety training, with updates for new or reassigned employees.
3.3 Access to clean toilet facilities, potable water, and sanitary facilities for food storage must be provided.
3.4 Accommodation, where provided, must be clean, safe, and meet basic needs.
3.5 Responsibility for health and safety must be assigned to a senior management representative.
- Prohibition of Child Labour
4.1 No child labour is permitted.
4.2 Suppliers must participate in policies and programmes to transition children found in child labour into quality education until they are no longer classified as children.
4.3 No person under 18 may work at night or in hazardous conditions.
4.4 Policies must align with relevant ILO standards.
- Payment of Living Wages
5.1 Wages must meet at least national legal standards or industry benchmarks, whichever is higher, and should always be sufficient to cover basic needs and discretionary income.
5.2 Workers must receive clear information about their employment terms and wages.
5.3 Wage deductions as a disciplinary measure are not allowed, and any deductions not mandated by law require the worker’s consent.
- Reasonable Working Hours
6.1 Working hours must comply with national laws and collective agreements.
6.2 Normal working hours must not exceed 48 hours per week.
6.3 Overtime must be voluntary, used responsibly, and compensated at a premium rate of no less than 125% of the regular wage.
6.4 Total weekly hours must not exceed 60, except in exceptional circumstances defined by local laws, collective agreements, and health safeguards.
6.5 Workers must have at least one day off in every seven-day period or two days off in every 14-day period where allowed by law.
- No Discrimination
7.1 Discrimination in hiring, compensation, training, promotion, termination, or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership, or political affiliation is strictly prohibited.
- Provision of Regular Employment
8.1 Employment relationships must comply with national laws and practices.
8.2 Obligations to workers under labour or social security laws must not be circumvented through labour-only contracting, subcontracting, or excessive use of fixed-term contracts.
- No Harsh or Inhumane Treatment
9.1 Physical abuse, discipline, threats, harassment, and intimidation are prohibited.
Safeguarding Within the Supply Chain
10.1 Suppliers must provide a safe and trusted environment that safeguards all individuals they interact with, including employees, volunteers, and beneficiaries.
10.2 Suppliers must cultivate a culture prioritising safeguarding, ensuring incidents and concerns can be reported and handled sensitively.
10.3 Adequate safeguarding policies and measures must be in place, understood, and shared within the organisation.
10.4 Procedures must outline how incidents and allegations will be addressed, including reporting to relevant authorities.
Compliance and Enforcement
Thomas Howse Ltd expects all suppliers to:
- Adhere to this Ethical Trading Policy.
- Comply with all national and applicable international laws.
- Where discrepancies arise between this policy and applicable laws, follow the provision offering the greater protection.
By upholding these principles, Thomas Howse Ltd and its suppliers demonstrate a shared commitment to ethical and responsible business practices.
Modern Slavery Policy
Modern Slavery and Human Trafficking Policy
Background
The Modern Slavery Act 2015, enacted in the United Kingdom on March 26, 2015, mandates that businesses operating in the UK publish a slavery and human trafficking statement for each financial year. This statement must outline the steps taken to ensure that slavery and human trafficking do not occur in the business or its supply chains. As an organization with operations in the UK, Thomas Howse Ltd fully adheres to the provisions of this Act.
Scope
This policy applies to all business operations of Thomas Howse Ltd. Employees involved in sourcing parts, components, and materials are integral to ensuring compliance with this policy, relevant legislation, and associated regulations. The policy undergoes an annual review, with updates incorporated as necessary.
Our Commitment
Thomas Howse Ltd is dedicated to upholding human rights, respecting the environment, and opposing corruption. We are committed to ensuring that slavery and human trafficking are eradicated from our business and supply chains. This commitment aligns with our Human Rights and Sustainability Policy and our Ethics Policy, which guide us in adhering to global standards of integrity and ethical practice.
Definitions
In alignment with the United Nations Global Compact (UNGC) and its Ten Principles, Thomas Howse Ltd supports:
- Protection and respect for internationally proclaimed human rights.
- Avoidance of complicity in human rights abuses.
- Freedom of association and the right to collective bargaining.
- Elimination of all forms of forced and compulsory labour.
- Effective abolition of child labour.
- Elimination of discrimination in employment and occupation.
- Adoption of a precautionary approach to environmental challenges.
- Initiatives to promote greater environmental responsibility.
- Development and diffusion of environmentally friendly technologies.
- Opposition to all forms of corruption, including extortion and bribery.
Key terms include:
- Supply Chain: Entities directly or indirectly contributing to Thomas Howse Ltd’s products or services.
- Due Diligence: An ongoing process to assess, address, and communicate human rights risks and impacts.
- Human Rights Risk: The potential for business operations to result in adverse impacts on human rights.
- Worker: Includes all individuals providing labour, whether directly employed, temporary, or contracted.
Our Expectations
Thomas Howse Ltd operates within a multi-tiered, complex supply chain. To ensure compliance with the Modern Slavery Act, we expect all suppliers to uphold the following principles:
- Prohibition of Forced Labour
- Suppliers must not engage in forced, bonded, or involuntary prison labour, or human trafficking.
- Workers’ identification documents must not be withheld unless legally required.
- Freedom of Movement and Employment
- Workers must have the freedom to leave their workplace and terminate their employment voluntarily.
- Employers must not mislead employees during recruitment or impose recruitment fees.
- Written Employment Terms
- Workers must receive clear, written employment agreements in their native language before starting employment.
- Supply Chain Compliance
- Suppliers must have a compliance plan to prevent forced labour and mitigate risks of worker exploitation.
- Suppliers are expected to conduct due diligence on their supply chains and assist Thomas Howse Ltd in compliance efforts.
Consequences of Non-Compliance
Thomas Howse Ltd reserves the right to reconsider or terminate relationships with suppliers who fail to comply with this policy or refuse to cooperate in our compliance efforts.
We remain steadfast in our commitment to eliminating modern slavery and human trafficking across our operations and supply chains. Through rigorous enforcement and collaboration with our suppliers, we aim to uphold the highest standards of human rights and ethical practice.
Privacy & GDPR Policy
Introduction
Thomas Howse Ltd collects and processes personal data relating to its customers and suppliers to manage initial and ongoing relationships. We are committed to transparency in how we collect, use, and protect that data, and to meeting our data protection obligations.
Information Collected
We collect and process the following information:
- Personal and Contact Information: Name, address, contact details, including email address and telephone number.
- Business Details: Company registration, VAT/EORI number, and terms of the relationship.
- Trading History: Details of current and previous trading history with us and third parties, tariff charges, and credit history.
- Payment Information: Bank account details for electronic payments.
- Credit and Solvency Information: Information about solvency, previous civil judgments, and credit risk.
- Company and Delivery Information: Company address, place of business (UK or international), and delivery locations.
- Marketing Data: Frequency and nature of trade for marketing purposes, updated quotations, and compliance information (e.g., MSDS).
- Risk and Suitability: Data for credit risk assessment and trade suitability.
We may collect this information through various methods, including “know your client” documentation, credit application forms, correspondence, meetings, interviews, or assessments. We may also obtain information from third parties such as Credit Risk Assessors, banks, trade references, and Companies House.
Data Storage
Your data is stored securely in client files, management systems, and IT systems, including email and back-office systems.
Purpose of Data Processing
We process your data to:
- Fulfill trading or service contracts, including providing forecasts, costings, delivery dates, quotations, proof of delivery, and safety information.
- Ensure compliance with legal obligations, such as Anti-Money Laundering and Financial Sanctions requirements.
- Manage legitimate business interests, such as maintaining accurate records, ensuring effective administration, and meeting regulatory requirements.
- Contact you for marketing purposes (e.g., new products, price amendments) with your consent. You can withdraw your consent anytime by contacting the data controller at sales@howsepaints.co.uk.
Data Access
Your information is accessible internally only to staff who require it to perform their duties. We may share your data:
- With third parties for services you have consented to (e.g., order delivery).
- In the event of a partial or full sale of our business, subject to confidentiality agreements.
- Outside the EEA if required for order fulfillment, shipment, or financial instruments processing.
Data Protection
We take the security of your data seriously. Measures include:
- Routine Data Privacy Impact Assessments by the Compliance Team.
- Procedures to detect, investigate, and report data breaches.
- Third-party processors working under written instructions, confidentiality obligations, and robust security measures.
Data Retention
- Data related to services undertaken is retained for six years from the last contract or direct contact.
- Data not leading to a contract is retained for one year before being archived.
- Credit history is retained for a maximum of ten years.
- Data from continuous trading relationships lasting five years or more may be retained indefinitely to meet legal obligations and provide evidence to tax authorities if required.
Your Rights
As a data subject, you have the right to:
- Access: Request and obtain a copy of your data (Subject Access Request).
- Rectification: Request correction of inaccurate or incomplete data.
- Erasure: Request deletion or cessation of data processing, subject to retention requirements for tax compliance.
- Objection: Object to processing where legitimate interests are the legal ground for processing.
For inquiries or to exercise your rights, contact us at sales@howsepaints.co.uk.
QEHSS Policy Statement
QEHSS Policy Statement
Introduction
Thomas Howse Ltd is dedicated to being a leading national and global supplier of paints and surface coatings. We uphold responsible business practices that reflect our reputation for integrity, quality, and responsibility. We are committed to exceeding customer expectations, ensuring the security, health, and safety of our employees, customers, and stakeholders, and minimizing the environmental impact throughout the lifecycle of our products—from design and manufacture to distribution, use, and disposal.
Commitments
We implement our Quality, Environmental, Health, Security, and Safety (QEHSS) responsibilities by:
- Prioritizing Customer Satisfaction and Safety: Integrating customer satisfaction, environmental, health, security, and safety considerations into business planning and decision-making processes.
- Providing a Secure Workplace: Ensuring a healthy, safe, and secure environment for employees, visitors, contractors, and the community.
- Sustainable Resource Management: Managing business activities to efficiently use natural resources, guided by the principles of sustainable development and Product Stewardship.
- Adopting International Standards: Utilizing systems aligned with international QEHSS standards, including ISO 9001, ISO 14001, OHSAS 18001, and Responsible Care (RC 14001) management systems.
- Ensuring Continuous Improvement: Driving consistency and improvement through transparency, monitoring, risk assessment, and performance verification.
- Regulatory Compliance: Meeting or exceeding the intent of all applicable QEHSS contractual and regulatory requirements and Thomas Howse Ltd’s global commitments.
- Setting Measurable Goals: Establishing KPIs, goals, targets, and objectives to continuously improve QEHSS performance, particularly in the development of new products and processes.
- Engaging Stakeholders: Involving employees and stakeholders by communicating, understanding, adhering to, and complying with the QEHSS policy and expectations.
- Promoting Open Communication: Maintaining open dialogue with customers, contractors, communities, and other stakeholders to align our QEHSS policies and Responsible Care performance with their needs and expectations. We also promote our QEHSS policy throughout the value chain.
Mr. Garry Plant
General Manager
Date: 8th December 2024
Corporate Social Responsibility (CSR) Mission
Corporate Social Responsibility (CSR) Mission
At Thomas Howse Ltd, we believe that a strong commitment to corporate social responsibility (CSR) aligns with good business sense and complements our core strategy and corporate values. Our CSR policy is guided by the following principles:
- Minimizing Impact and Maximizing Benefits: Reduce the environmental and social impact of our work and products while enhancing their positive contributions.
- Integrating CSR into Business Decisions: Incorporate CSR considerations into every business decision.
- Compliance and Excellence: Comply with, and where practicable, exceed all applicable legislation, regulations, and codes of practice.
- Continuous Improvement: Annually review, report on, and strive to enhance our CSR performance.
By setting this policy and developing our strategy, we aim for gradual and continuous improvement in our performance each year. Our approach evolves as we learn and grow. To outline our commitment, we focus on four key aspects:
Community
We aim to make our local community a better, safer, and more compassionate place to live. We actively:
- Collaborate with local community groups to address identifiable needs.
- Encourage employees to use their skills for community benefit.
- Partner with local businesses to maximize positive impact and avoid duplication of efforts.
People
We are committed to fostering personal and professional growth for every employee by:
- Developing their skill sets and improving working conditions.
- Encouraging contributions, recognizing efforts, and involving everyone in change processes.
- Enhancing economic well-being and creating a sense of worth and belonging among all employees.
Environment
We take responsibility for understanding and managing our environmental impact ethically. This involves:
- Collaborating with stakeholders, including shareholders, directors, suppliers, customers, employees, and local authorities.
- Committing to mitigate any negative environmental effects in the communities where we operate.
Responsible Manufacturing and Trading
We maintain and improve the highest standards across our operations by:
- Opposing exploitation and eradicating abuse in all forms.
- Recognizing and promoting the value of every individual, everywhere, all the time.
- Ensuring an ongoing process of improvement and fostering shared values among employees, suppliers, customers, and stakeholders.
A Living Mission
Real, meaningful, and effective CSR is not just a policy—it is our mission. You should feel it when you walk through our front door, see it in the communities where we operate, and hear it in conversations with our employees and stakeholders.
Thomas Howse Ltd
Date: December 8th 2024
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