Allegations and Misconduct Policy

Updated January 2022

People Solutions Ltd t/as Action First follow stringent quality guidelines and takes every reasonable precaution to ensure that all candidates deployed to the Client maintain the highest standards of professional and personal conduct. Our stringent vetting procedures ensure that any candidate found to have a history of unacceptable conduct or practice, will not be offered a place on our register. Through our continuous and active monitoring, any difficulties our candidates may be experiencing are promptly highlighted, enabling us to step in and pre-empt potential issues.

However, despite our stringent quality procedures, and the vulnerable position that agency staff often find themselves in, occasionally difficult or sensitive issues may arise. Both Client and candidate feedback is essential to us in order to ensure we continually work towards improving our service. In the event of more serious allegations, for example: Physical assault, a verbal offence or discrimination Action First Assessments Ltd t/as Action First has set out the following procedures which MUST be adopted by when dealing with incidents of this nature.

Any candidate who has a complaint made against them is automatically suspended and not placed with another client until the matter has been fully resolved.

Procedure

Action First Assessments Ltd t/as Action First has a central file in which staff can record the details of any allegation or complaint against a candidate, together with a detailed account of all actions taken in the course of any investigation. Copies of statements and all correspondence are kept as well as a chronological sequence of events and are maintained and reviewed by the Director responsible for the compliance function. Following the receipt of a complaint or report of an incident, we would explain that we have certain procedures for handling incidents and that we will be happy to set these in motion if the client/candidate would like us to do so. In deciding how far to pursue the investigation, we are usually guided by the client's/candidate's attitude to the incident . If the incident is considered serious enough to warrant further investigation, we adopt the following procedure:

Stage 1

• Does the client wish to terminate the arrangement for the worker's services immediately?
• Does the client wish to retain the candidate's services pending investigation?
• Does the client require a replacement candidate?

Stage 2

• Inform the client that we will conduct our own investigation of the incident by interviewing the candidate in the presence of their Union representative/Colleague/Independent representative (We always advise the candidate that we have been informed of an incident and ask for their version of events, prior to telling them what has been stated by the client.
• Prior to such investigation, we request a written statement from the client, together with any supporting statements outlining the nature of the allegations.
• Following such investigation, we will record the response of the candidate and report back to the client.

Stage 3

Following receipt of a written report from the client, we write to the candidate concerned and ask him/her to attend a meeting at our office. We advise them that it would be in their own interest to be accompanied by a representative.

Stage 4

We contact the client informing them of the steps we have taken.

Stage 5

We arrange a meeting and ensure that 2 representatives (one to conduct the investigation and the other to act as a witness and note taker) are present:

• Introduce parties to each other
• State that this is not to be regarded as a disciplinary procedure, merely an investigation of a formal allegation which we have received.
• The details of the allegation are presented at this point (copies are handed out only with prior consent from the client) and the candidate is invited to comment.
• The candidate's comments are noted and read back to them for confirmation that we have noted the response accurately. If the candidate accepts responsibility for their actions and expresses regret, we give advice as to the dangers of laying himself/herself open to allegation. We also draw attention to our Code of Conduct and explain that the future of the candidate registered with our company will be dependent on his/her acceptance of and adherence moving forward to the Code. If, however, the candidate denies the charge, we simply note his/her comments and say that we will report these back to the client. We inform them that following this meeting, the client may or may not wish to pursue matters and that we will keep them informed of further developments.

Stage 6

Following the meeting we will then write to the client to report on the outcome of our investigation. The client is advised that if the matter cannot be resolved and that the seriousness of the allegation warrants further action, to adopt whatever measures would normally come into force to meet legal requirements. During the course of any such proceedings a Director of Action First Assessments Ltd t/as Action First will attend, if requested, any meetings to share information and co-operate fully with the Authority pending a final decision. All internal paperwork will also be made available. Following the outcome of any such investigation, we are guided by the Authority's decision when considering the candidate's future as a member of our register.

Post-Registration

If Action First Assessments Ltd t/as Action First receives information following registration of a candidate which may be relevant to his/her suitability for a post within our client/s, we would first assess its severity. If it is apparent that the information is of a serious nature then we would notify all relevant parties immediately and implement the following procedure:

• Managers will immediately refer the matter to their Director.
• Any serious acts of misconduct will be dealt with by the Director.