HR Newsletter No. 153 – Further Statutory Figures

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Statutory Figures

The annual increase in compensation limits has been announced on the same day as the Budget announcement. The limits apply to dismissals, including redundancies, occurring on or after 6th April 2023.

  • £643.00 – the maximum amount of a week’s pay for calculating statutory redundancy pay and the basic award; (up from £571.00);
  • £19,290.00 – the maximum statutory redundancy payment or basic award, i.e. 30 weeks (up from £17,130.00);
  • £105,707.00 – the maximum compensatory award which can be made for unfair dismissal (up from £93,878.00) or one-year’s gross pay whichever is the lower;

These increases mean that the maximum total unfair dismissal award is now £124,997.00; although uplifts can add a further 25%.

Employees may be entitled to receive guarantee payments for up to five days of lay off in any three-month period.  The maximum amount of such a Statutory Guarantee Payment will increase to £35.00 (up from £31.00) for any one day.

The new rates take effect where the ‘appropriate date’ for the cause of action (such as the date of termination in an unfair dismissal claim) falls on or after 6th April 2023.

 

 

 

 

Our Consultants would be pleased to advise you on any element of the issues arising from this newsletter.

The information provided in this article was correct at the time of publishing.

 

Back in 2015, we sent out Newsletter No 97 about the right of employees to be accompanied at any grievance meetings.  We are now in 2023 and certain aspects have now changed, so we have produced this update.

An employee who is invited to attend a grievance meeting has the right, under the Employment Relations Act 1999, section 10, to be accompanied by an accredited “trade union official or a fellow worker.”

When inviting an employee to a grievance meeting, the employer should inform them of their statutory right to be accompanied.  There are a number of things you need remember when dealing with an employee’s right to be accompanied. Much of which can be found in guidance from ACAS:

(1) Not every grievance related meeting attracts the right to be accompanied. When an employee raises a formal grievance, the subsequent meeting you will have with them does mean that they have the right to be accompanied. This meeting is to hear their grievance in full, and to establish whether there is evidence that supports their claim. This could be classed as a type of investigation.  If what they raise at that meeting requires further investigation, then it is important that this happens. So, any other follow up meetings with that employee about their grievance will also incur the statutory right of accompaniment.  However, other investigation meetings, when you are interviewing other witnesses to establish whether the initial grievance claim has merit or not, does not require you to allow those employees to be accompanied, unless your policy says so.

(2) Employee’s requests to be accompanied must be reasonable. Situations where the request may not be reasonable include, where their chosen companion will not be available to attend a meeting within a reasonable time, for example because of illness, holiday, work or other commitments. The issue of the reasonableness of the request is a matter of fact in the particular circumstances. Employers should carefully justify any rejection of a request by reference to the principles of the ACAS Code of Practice on Disciplinary and Grievance Procedures, including the need to deal with matters promptly and without undue delay.

The companion must be chosen by the employee and can be a fellow employee, or a trade union official who has been certified by the union as having experience of, or having received training in, acting as a companion at such meetings. There is no necessity for the trade union official’s union to be recognised in the workplace, nor is there any obligation on employees or union officials to accept a request to act as a companion.

(3) The employer cannot object to the employee’s choice of companion, so long as the companion is willing, and is available. We would recommend that in making their choice, employees should be told to bear in mind the practicalities of the arrangements.

(4) If the companion is not available at the proposed meeting time, and the employee suggests another time that is reasonable, and falls within five working days of the original time, the meeting must be postponed. The new time can be proposed by either the employer or employee.  If the employee again states that their chosen companion is not available, then the employer can recommend they find another companion so as not to postpone matters any further, beyond the initial week’s delay. Trade Union officers are busy people, so if the delay is only for a matter of a couple of further days, it may be advisable to accept a short further delay to appear reasonable.

(5) The companion should be allowed reasonable paid time-off to carry out the role. They are permitted to take a reasonable amount of paid time off during working hours to accompany a colleague, and to prepare and confer with the employee before, and after the meeting. They may present a complaint to a Tribunal if the employer fails to pay them for the time off.

It is important for employers to ensure that an employee advises their employer in advance, of the identity of the person they would like to bring to the meeting as their companion, so that the employer can ensure their availability and support for the employee.

(6) Ensure you understand what the companion can do at the meeting. Employers often mistakenly believe that the companion is there simply to provide moral support, and act as a witness for the employee, but can take no active part in the meeting.

The companion, if they so wish, must be permitted to address the meeting in order to put the employee’s case, they can sum up the case and respond on the employee’s behalf to any view expressed at the meeting. The companion must also be permitted to confer with the employee during the meeting.

A companion can also take notes of the meeting on the employee’s behalf. This may sometimes lead to two versions of the notes, if the version of the employer’s notes is disputed by the employee, based on their understanding of what was discussed at the meeting.

However, the companion has no right to answer questions on behalf of the employee, to address the meeting if the employee does not wish them to do so, or to prevent the employer explaining its case.

(7) If the employee going through the grievance process is disabled, reasonable adjustments may need to happen, such as allowing a companion from outside the normal permitted categories. Permitting companions of this nature can be a sensible policy for employers, as their presence may help put the employee at ease, and assist in getting to the facts of the matter under consideration. If English is not the employee’s first language and they have a known language problem, then having a companion present that can translate for them is strongly advisable but preferably find someone in-house if possible.

(8) There may be adverse legal consequences if an employee is refused the right to be accompanied. The employee can complain to an Employment Tribunal. Where the complaint is well founded, the Tribunal will order the employer to pay up to two weeks’ pay as compensation (subject to the statutory cap on the amount of a week’s pay). The right to be accompanied does not depend on the length of time an employee has worked for/with the employer.

(9) It is not necessary for an employee to make a request to be accompanied in writing, or within a specific timeframe. However, employees should be encouraged to make their requests clear, and provide their employer with the name of their chosen companion, as well as confirming which category of approved companion they fall in to.

(10) Unless contractually entitled, employees have no statutory right to be accompanied by a family member at a grievance meeting, unless the family member happens to be a work colleague or trade union official, in which case, they will be a permissible companion under the statutory right to be accompanied.

However, there is nothing to prevent an employer from allowing an employee to be accompanied by a family member, and it is likely to be appropriate in the case of a young person under 18 years old or a particularly vulnerable employee.

(11) The conduct of any companion may be considered as part of their normal duties, so blatantly disruptive or inappropriate behaviour should attract any appropriate action against the companion, as an employee, in their own right.

 

Finally, many employers are nervous at the prospect of holding a grievance meeting when the chosen companion is an accredited trade union representative.  Don’t be would be our advice.  Full time union officials are very experienced at these types of meetings, and tend to be refreshingly objective and non-emotive, which invariably helps the employer to get to the real heart of the matter.  They will have also encouraged the employee to be clear about what they wish to achieve having raised the grievance.

If you feel that you need professional assistance to ‘balance things up’ then we would be happy to assist.

 

Our consultants would be pleased to advise you on any element of the issues arising from this newsletter.

All information provided in this newsletter was correct at the time of publishing.

In 2023, there will be an additional Public/Bank Holiday to mark His Majesty’s Coronation.  The Coronation is actually on Saturday, 6 May so the Public/Bank Holiday is the following Monday, 8 May.  This means there will be 3 Public Holidays in May 2023.

For England and Wales, the schedule for 2023 looks like this:

Date                       Public Holiday (Dates in italics are not the official holiday)

2 January                New Year’s Day (substitute day)

7 April                      Good Friday

10 April                   Easter Monday

1 May                      Early May Bank Holiday

8 May                      Bank holiday for the Coronation of King Charles III

29 May                    Spring Bank holiday

28 August                Summer Bank holiday

25 December           Christmas Day

26 December           Boxing Day

All employees are entitled to a set number of days off work each year by way of paid leave. The minimum statutory annual leave entitlement is 5.6 weeks’ paid holiday per year, which is equivalent to 4 weeks plus 8 Public/Bank Holidays. An employer may offer enhanced rights over this legal minimum under the terms and conditions stated within their employment contracts.

However, by law, Public or Bank Holidays do not have to be given as additional paid leave, although an employer can choose to include Public/Bank Holidays as part of an individual’s statutory annual leave entitlement. If so, this essentially means that if your place of work is closed on some or all Public/Bank Holidays, you can require employees to take these days as part of their paid holidays. Equally, you may choose to pay your employees for Public/Bank Holidays on top of their normal leave entitlement, or allow employees to take them as extra holiday days, but without pay.

In the context of any organisation that remains open on a Public/Bank Holiday, it’s again up to the employer to decide whether or not an employee needs to work those days.

In essence, the rules relating to whether employees are asked to work, or not, Public/Bank Holidays, and whether or not any Public/Bank Holidays are included in the overall paid annual leave entitlement, are a matter of what is clearly expressed in the contract of employment. Whether Public/Bank Holidays are in addition to, or inclusive of the employee’s statutory or contractual annual leave entitlement, will depend on the wording within the contract of employment.

Entitlement to the additional Public/Bank Holiday in 2023

It is important to note that employees do not have an automatic right to paid time off for an extra Public/Bank Holiday. Employers are advised to check the wording of their employment contracts, and communicate with employees about whether or not they will be required to work on the additional Public/Bank Holiday in line with the terms of their contract.

We have set out below the most commonly used phrases relating to Public/Bank Holidays that we have seen in employment contracts, and what they mean in terms of the employee’s right to have paid time off work on 8 May 2023.

Contractual wording Entitlement to paid time off for an additional Public/Bank Holiday
1.

“20 days holiday per annum plus Public/ Bank Holidays”

 

 Yes – employees will have a contractual entitlement to take paid time off on the additional holiday as the wording on holiday entitlement in the contract is not limited to the normal/usual Public/Bank Holidays. Therefore, there is a contractual entitlement to paid time off on all Public/Bank Holidays – including Public/Bank holidays which are in addition to those normally observed.
2.

“28 days holiday per annum”

 

 Potentially – where the contract is silent on Public/Bank Holidays, the employee has the ability to request booking from their 28-day holiday allowance any of the Public/Bank Holidays, including the additional Public/Bank holiday, subject to Management approval. However, there is no increase in holiday entitlement as a result of the additional Public/Bank Holiday.
3.

“20 days holiday per annum plus 8 Public/Bank Holidays”

 Potentially – similar to above.  The contract is silent on which Public/Bank Holidays are included within the employee’s holiday entitlement, and, therefore, an employee has the ability to request booking the additional Public/Bank Holiday as paid time off in May 2023. Although this would mean that the employee will not be entitled to one of the later Public/Bank Holidays in the year. We would recommend this is clarified to the employee at the time of booking annual leave.
4.

In addition, you will also receive pay on or in respect of each of the eight Public/ Bank Holidays as listed below:

           
New Year’s Day, Good Friday, Easter Monday May Day, Spring Bank Holiday, Late Summer Holiday, Christmas Day, Boxing Day.

 No – where there is a list of Public/Bank Holidays contained within the contract, the employee will only be entitled to receive paid time off on those named Public/Bank Holidays listed (whether this list is some or all of those usually observed in England and Wales). Employees with such wording in their contract will not have a contractual right to the King’s Coronation Public/Bank Holiday of 8 May 2023, only by the discretion of the Employer.
5.

“20 days holiday per annum plus the usual Public/Bank Holidays observed in England and Wales”

 No – as the additional Public/Bank Holiday is not usually observed in England and Wales, so employees would not be entitled to take paid time off on the additional Public/Bank Holiday.

The wording at point 4 above is what most of our clients will have, although it is important that you check your templates versions.

Even where there is no contractual entitlement to take the additional Public/Bank Holiday as paid time off, many employers, as a gesture of goodwill, will decide to allow their employees to take the additional holiday.  If that is not possible for operational reasons, an employer may choose to provide time off in lieu as an alternative. The goodwill lost through not offering an extra day’s leave in 2023 will often far outweigh any marginal cost savings gained from not giving the day off, or from requiring employees to take the extra day from their existing holiday entitlement.

Previous approach to time off for additional Public/Bank holidays

In 2022 we had the Queen’s Platinum Jubilee in June and then unexpectedly the Queen’s Funeral in September.

Therefore, when considering whether to allow employees paid time off for the additional Public/Bank Holiday in 2023, we would recommend considering what has been done previously. If employees have previously been offered paid time-off, or time-off in lieu to mark an additional Public/Bank Holiday, to adopt a different approach in respect of the 2023 additional Public/Bank Holiday may cause a negative reaction from employees (in particular, those with long enough service to have been working when this happened previously).

Requests for time off work

Even though employees have a right to a minimum number of paid days holiday each year, employees are not normally entitled to pick and choose when they take this time off. Employers need to manage staff rotas to ensure that they have the necessary available cover at all times to ensure business continuity.

To maintain good employee relations, it’s important for employers to handle any requests for time off fairly and consistently. As an employer, you should also be prepared for an influx of annual leave requests covering the two weeks linked with Monday,1 May and Monday, 8 May 2023 Bank holidays.  If your workplace closes on weekends and Public/Bank Holidays, the extra Public/Bank Holiday will probably mean that many of your employees will seek to benefit from 9 consecutive days off work. As it is highly unlikely that you will be able to accommodate every request, a strategy will need to be considered in advance.

The three key considerations will be:

  • Decide on a fair approach whilst balancing operation needs;
  • Early communication about whether or not certain groups of the workforce may, or may not, be required to work the additional Public/Bank Holiday in line with stated contractual terms;
  • Set a start date and deadline for holiday/time off requests;

Hospitality businesses should also take note that the Government has proposed extending licensing hours from 11.00 p.m. to 1.00 a.m. over the bank holiday weekend of the Coronation in England and Wales. Employers will need to prepare for this early on if they intend to ask staff to work longer hours, and decide if they will offer extra hours, perhaps with an overtime premium attached or if there are any relevant contractual clauses for compulsory overtime they could enforce (where it is reasonable to do so).

 

 

Our Consultants would be pleased to advise you on any element of the issues arising from this newsletter.

All information provided in this newsletter was correct at the time of publishing.

There are some important changes to statutory rates of pay that the Government have already announced, to take effect in 2023.

National Minimum/Living Wage Rate Increases & Accommodation Rate

The National Living Wage is to rise by 9.7% which is the biggest cash increase ever. It will go from £9.50 to £10.42 per hour.

At the same time, the National Minimum Wage (NMW) rates will be increased as follows:

  • from £9.18 to £10.18 per hour for 21 to 22-year olds;
  • from £6.83 to £7.49 per hour for 18 to 20-year olds;
  • from £4.81 to £5.28 per hour for 16 & 17-year olds; and
  • from £4.81 to £5.28 per hour for apprentices;

Accommodation Rate

If you provide some form of staff housing as part of the contractual arrangements, then the daily accommodation offset will apply. This will change from the current rate of £8.70 per day to £9.10.

The effect of accommodation rates on the National Minimum Wage or National Living Wage depends on how much an employer actually charges for accommodation.  It’s calculated by ‘pay period’, the frequency interval that someone is being paid. If the accommodation is free, it still affects the minimum wage.   It does not matter if the cost of the accommodation is taken from the worker’s wages beforehand, or if the worker pays the cost after they get their wages.

Some examples the Government website provides is based on the current rate:

Example 1: accommodation is free

John is 24 and gets £7.60 an hour. This is below the National Living Wage (which he should get as he’s over 23). He works 30 hours a week. He gets paid every 7 days (his pay period). His employer provides free accommodation 7 days a week. This brings John’s pay up to £9.63 an hour, which is above the National Living Wage of £9.50.

Calculation:

  • £8.70 (offset rate used when accommodation is free) × 7 (days accommodation provided in pay period) = £60.90
  • £60.90 + (£7.60 × 30 – the total pay in reference period) = £288.90
  • £288.90 ÷ 30 (total hours in pay period) = £9.63

Example 2: accommodation is charged below the maximum rate

Lisa is 22 and gets £9.30 an hour. This is above the National Minimum Wage. Her employer charges £6.50 per day for accommodation which is below the threshold of £8.70. No offset rate is applied.

The accommodation charge does not affect Lisa’s pay of £9.30 an hour.

Example 3: accommodation is charged above the maximum rate

Sam is 35 and gets £9.60 an hour. This is above the National Living Wage (which he should get as he’s over 23). He works 40 hours a week. He gets paid every 3 weeks (his pay period). His employer charges £9.50 per day for accommodation. Sam lives in the accommodation full time which is 21 days for his pay period.  This brings Sam’s pay down to £9.46 an hour, which is below the National Living Wage.

Calculation:

  • £9.60 (hourly rate) × 120 (total hours in pay period) = £1,152
  • £9.50 (accommodation rate) × 21 (days accommodation provided in pay period) = £199.50
  • £8.70 (offset rate used when accommodation is free) × 21 (days accommodation provided in pay period) = £182.70
  • £1,152 (total pay in pay period) – £199.50 (total accommodation cost in pay period) + £182.70 (total accommodation offset in pay period) = £1,135.20
  • £1,135.20 ÷ 120 (total hours in pay period) = £9.46

Increased Statutory Rates

The rate for 2023/24 for Statutory Maternity (SMP), Paternity (SPP), Adoption (SAP), Parental Bereavement (SPBP) and Shared Parental (SShPP) Pay are set to increase from £156.66 to £172.48 per week.

Additionally, the rate of Statutory Sick Pay (SSP) is also set to increase from £99.35 to £109.40 per week.

The average earnings an employee has to earn to be entitled to these payments will remain at £123.00 per week.

The rates for Statutory Redundancy Pay, Statutory Guarantee Pay, and Tribunal Awards are not yet announced.  We will send an update as soon as the new rates are published. They are usually expected in March.

Implementation

Exact dates of implementation are still to be confirmed, and it is worth noting that they do not all usually increase on the same date. It is expected that SMP, SPP etc. will increase on 2 April 2023, and SSP will increase on 6 April 2023. The NLW and NMW rates go up from 1 April 2023.

Extra Public/Bank Holiday in 2023

We will be sending out a separate newsletter shortly on this which will give you more information.

Changes to Existing Rights

Flexible working

There have also been some well published amendments to existing rights that may become law in 2023. Flexible working has been given a lot of attention following increased interest in hybrid working, and the Government’s announcement that they want to make it the “default” position. To do this, the Government have committed to the following changes.

  • Make flexible working a day-one right.
  • Require employers to consult with the employee before rejecting a request.
  • Allow two flexible working requests in any 12-month period.
  • Shorten response time to two months.
  • Remove need for employees to set out how the employer will deal with impact of request.

This is hoped to make flexible working more accessible, and the process less onerous on the employee. Crucially, however, it does not give employees any greater rights to demand flexible working. Instead, it requires more from employers during the process of negotiating flexible working, and places them under a greater burden if intending to refuse the request (such as the need to consult).

Redundancy protection

Under current rules, before offering redundancy to an employee on maternity, shared parental or adoption leave, employers have an obligation to offer them a suitable alternative vacancy where one exists. The proposal is that this protection will apply through an expanded period covering from when a woman tells her employer she is pregnant until 18 months after the birth. The 18-month window ensures that a mother returning from a year of maternity leave can receive six months of additional redundancy protection. The 18-month window will also apply to adoption and shared parental leave.

EU law

Finally, UK employment law is on the brink of massive change and we cannot yet say exactly what impact this will have. Legal changes have been proposed to “deal with” EU law that remain in place in the UK. The Retained EU Law (Revocation and Reform) Bill will automatically repeal retained EU law on 31 December 2023 unless legislation is introduced to keep it.

Laws that could change or expire include the following.

  • TUPE (unlikely to be scrapped, but could be amended to allow harmonisation of terms).
  • Rights to paid annual leave (such as how to calculate a week’s pay).
  • Maximum 48 hour working week.
  • Agency worker regulations.
  • Part-time and fixed-term worker regulations.

There are also nearly 60 pieces of European Health & Safety legislation that if repealed would have a significantly detrimental effect on the workplace.

Future Legal Rights

A number of Bills giving new rights are on their way to become law. However, due to the nature of this process, it is not possible to say with certainty if this will happen this year, or what the details of these new rights will be, as they may still be changed. Nevertheless, it is important to be aware of what might be coming so that initial plans can be prepared.

Carer’s Leave

One of these rights is that of carer’s leave. This new right, if passed into law in its current form, will give unpaid carers the right of up to a week of unpaid leave per year, to be used to provide care for someone dependant on them. This is similar to the existing right to time off for dependants, differing however in its time limit of “up to one week per year”.

Neonatal Leave and Pay

Another new right that may potentially come into law in 2023 is neonatal leave and pay. This right, applicable from day one but subject to a qualifying criterion for pay, will allow parents of very sick babies (defined as those admitted to hospital up to 28 days after birth, requiring a continuous stay of seven days or more) a period of up to 12 weeks leave to be with their baby in neonatal care. This will be taken in addition to existing maternity/adoption/paternity rights.

Tips

Another new right that is expected to come into law is one that will allow workers to keep 100% of tips and gratuities paid to them, whether by card or cash, or as a service charge. Employers will be under a duty to keep accurate records of tips distribution; employees will have a new right to bring a claim if not.

 

Our consultants would be pleased to advise you on any element of the issues arising from this newsletter.

One of the biggest challenges facing small employers revolves around managing the long term sick and the disabled.

To help clarify employers’ duties, the HSE has published new guidance. It is based around the principle that every member of staff is entitled to good health and safety practice, especially those who are disabled or suffer from protracted health conditions.

As we face a talent shortage, this new guidance is focused on support for such workers, helping them find and stay in work.

They have split their key principles into 8 sections – an overview and then 7 crucial areas that are explained in depth, and which can be read on their website here.

One to one consultations and conversations

In all situations, employers need as much information as possible about their workers’ situations and challenges.

So, start with open and honest conversations with them, which typically start at return to work meetings, and during periods when people are off on long term illness. Policies should make it clear that it is an employee’s responsibility to keep in regular contact with their employer, and Managers need to not shy away from such conversations.

These are often more effective if held on a one-to-one basis, allowing Managers to listen carefully to what the employee feels they need, and agreeing a course of action with them.

Once the employer understands a worker’s needs, they can make suitable, reasonable workplace adjustments. This might include significant changes to the way they work, or support for their return to work.

Supportive and “enabling” workplaces

The HSE places great emphasis on how the right workplace culture can create the right environment for all workers to flourish.

But this does not just happen because the organisation says so; Managers need to be accessible, so they can listen and help their staff. In particular, they need to understand the pressures and challenges affecting staff at work and outside.

The HSE also talks about the dilemma we all face, knowing enough to be able to help and to remove barriers that disadvantage them, while respecting worker privacy and confidentiality and dignity.

They also suggest signing up to the Disability Confident Employer Scheme.

Inclusive approach

Truly inclusive workplaces can lead to increased productivity, a larger talent pool, greater creativity and more innovation.

Workplace practices must also be fit for purpose. With employers giving clear, concise, easy to understand instructions that can easily be followed by all workers. Such an approach is crucial to identifying and removing workplace barriers.

Providing additional advice

For the employee, the government provides some good advice of their own – Access to Work.

But employers should not rely on just this; they should have their own advice schemes. Provided, where appropriate, through access to their own HR professionals, and not forgetting Occupational Health providers.

Providing access to free counselling services is an increasingly useful benefit for employees, and is not as expensive as many employers believe, if you shop around.

Work barriers and their impact

Employers need to step back and look at some of the work barriers people face. Not only do these affect recruitment, they also prevent the effective integration of new recruits, and continue to affect staff throughout their careers.

Focusing on what workers can do is far more effective and encouraging than highlighting what they cannot do.

The HSE discusses barriers that are physical – they cite as examples poor access to buildings, or poor toilet facilities, or even, for remote workers, video calls with no subtitles. Perhaps the organisation has not invested in or enabled IT that supports text reading.

Or, the barriers can be organisational – perhaps your sickness and absence policies are too rigid and do not consider each person with their own individual needs. They can be attitudinal – assuming workers cannot add anything in certain areas, or that they would not want to attend social gatherings.

Workplace adjustments

Many employers struggle with the concept of workplace adjustments. But remember, these have to be reasonable and putting them in place may be much less disruptive than having to recruit and train new staff members.

And, many adjustments do not really cost anything, they just need a new mindset. Things like new shifts or work patterns, assistive software, a phased return to work and improved communications. And, quite often, the solution is a temporary one anyway, especially if the long-term convalescent returns to full productivity, or the disabled worker needs time to adjust.

The HSE recommends recording such agreed adjustments in a ‘passport’, which we would call a return to work plan that is regularly reviewed thereafter. This is especially useful when workers’ jobs or Line Managers change.

Reviewing modifications

When a work activity or workplace changes, make sure that you review them. Further adjustments may be needed, or they may cease to be relevant.

Communications

Some workers may have sensory problems, dyslexia or even have never learned to read.

So be careful when you know this to be the case. Make sure you look at the format, medium and content. Useful support tools can include British Sign Language, Easy Read, and audio to text.

There should also be sufficient contrast levels between the background and text. Formats must also be accessible to screen readers/voice-overs and other assistive technologies.

Support for Managers

Managers need support too. Do not forget to give the appropriate training to understand how to support their staff. And, make sure they have the right support when team members are not as productive as they might be.

Sickness absence and a return to work

In these challenging times, it is sometimes tempting for staff to just plough on regardless. Especially when sickness policies mean absence will make a real impact on their earnings.

Likewise, active support for an absent worker encourages a return to work. It reduces the risk of someone eventually stopping work altogether, especially if they have been off for a long time.

Contact during sickness absence

Keep in touch. Not only do you have an interest in your workers welfare, you also have a responsibility to them. Regularly check any worker on sickness absence, assessing their wellbeing and making them feel valued and remembered.

Occupational health support

Occupational health services can help with workplace assessments and adjustments, advice on referrals to rehabilitation and support services, advice on returning to work and help to promote good health.

A return-to-work plan

A crucial part of any long-term sick employee’s reintegration. It should be prepared with their input and agreement before they return to work.

Workers need not necessarily resume their normal levels of activity and a supported return can aid their recovery.

Comment by BackupHR

The HSE have long been criticised for overly focusing on the prevention, where possible, of physical health caused by accident or injury, and have only more recently focused on issues such as mental health.

With the Government also vocalising on wanting to encourage more long-term sick people back into the workplace, this document is welcome, if somewhat tardy in its appearance.

 

 

Our Consultants would be pleased to advise you on any element of the issues arising from this newsletter.

There have been some significant changes to fire safety, through the Fire Safety Act 2021 which came into force on 16th May 2022.

However, these changes will only apply to organisations that own, run, manage or are otherwise responsible for multiple dwelling residential buildings. We do know, however, some of our clients are in that position.

The original fire safety legislation, or Fire Safety Order, was put into law in 2005, and was primarily designed for non-domestic buildings. However, it did include residential facilities, where they had multiple dwellings, or other premises such as hotels and care homes. But in these cases, responsibility for the areas outside of those dwellings was unclear, or at least open to interpretation.

So, as a result of Grenfell, and an increasing awareness about the risks of fire safety using some of the modern insulating materials, legislation has been passed to bring multiple dwelling, residential properties much more in line.

While it was clear that “Responsible Persons” had responsibility for common areas as well as the individual dwellings themselves, there was a lack of clarity in the law over how to treat the exterior of multi-occupancy dwellings. Particularly cladding, balconies and fire escapes.

This new legislation makes it clear who is responsible for these areas, and what responsibility they have, putting beyond doubt “that structure, external walls and flat entrance doors fall within the scope of the Fire Safety Order”.

Action Points

Organisations and Responsible Persons need to do the following:

  • Decide whether the new Fire Safety Act applies to premises they are responsible for;
  • Review current risk assessments for affected premises to ensure they reflect the changes and “Best Practice”;
  • Train those undertaking fire risk assessments, making them aware of the new guidance;
  • Ensure they are competent to apply such guidance;
  • After carrying out fire risk assessments, make sure all recommendations are reviewed;
  • That action is taken to reduce fire risks;

The enforcing authorities will be publishing “Best Practice” guidance. They will expect organisations to have followed it, or to have taken actions that demonstrate they understand the guidance and are complying with it.

Fire is a serious hazard that all organisations must consider within their Workplace Risk Assessments.  This is why we always recommend that clients appoint an external fire safety expert to undertake fire risk assessments, as there are many technical, building and workplace considerations to include when assessing fire risks. It is highly unlikely that clients will already employ someone in house with sufficient fire safety knowledge and competence.

As the Law continues, quite rightly, to tighten up on fire safety for both workers and residents, this is another reason for using external professional expertise, who typically are former or retired fire brigade officers.

 

Our Consultants would be pleased to advise you on any element of the issues arising from this newsletter.

The Health and Safety Executive (HSE) has recently published a 10-year strategic plan “Protecting People and Places” to build on the U.K.’s excellent safety record, and to expand its responsibilities.

After being heavily criticised for its faltering response during the first year of the pandemic, the HSE wants to ensure that its future focus is better targeted and more wide-ranging. A tough balancing act.

It’s five key objectives are listed as:

  1. Reducing work-related ill-health, especially mental health and stress.
  2. Making sure that the public feels “safe where they live, where they work, and in their environment”.
  3. Ensuring that health and safety legislation does not prevent innovation and progress.
  4. Maintaining the UK’s exceptional safety record by “learning from evidence and past events to protect people”.
  5. Ensuring that the HSE attracts and retains a highly skilled and capable workforce.

These are very grand aims. And, according to the HSE, they reflect the changing world of work and legislation. Among other things, they will be establishing a Building Safety Regulator, and take on more responsibilities for chemical regulation.

Mental Health

As part of their first objective, they have said they will treat mental health as seriously as physical health, and will be looking at the actions of employers in this regard. They see this as especially important when there is so much coverage in the media regarding mental health, stress and depression, particularly following the pandemic.

This work has already begun – Sarah Newton, Chair of the HSE Board, said ‘We worked with and listened to experts from MIND, ACAS and the Federation of Small Businesses, and last month achieved the milestone of 500 champions for our campaign to increase awareness of the risks of work-related stress and encourage businesses to take action.’

500 champions are all well and good, but many of these are fundamental problems, going to the heart of organisations. The danger is that people will just train and appoint Mental First Aiders thinking this is sufficient, when it is invariably just a sticking plaster on a festering wound.

Change of Direction

It is also worth pointing out that this is a significant change of direction for the Executive, as previously Inspectors appeared to rather shun the notion of Mental Health falling within their domain. And their second aim, concentrating on the home and the environment, as well as the workplace, is a considerable widening of their focus.

Commentators have pointed out that this has been brought about, in part, by the Grenfell enquiry, and it is worth remembering that it was 5 years ago this month that this terrible tragedy occurred. For the Grenfell survivors and relatives, they feel that they are still a long way away from achieving justice for loved ones lost.

But, the pandemic has also changed how individuals feel about their safety and their attitude towards risk, both at home and in work. And hybrid working means that the lines between home and the workplace are increasingly blurred.

People tend to feel safer working in their own homes, but familiarity can breed contempt. As an example, the HSE has reported a significant rise in musculoskeletal disorders (MSDs) in the last year alone, arising mainly from poor ergonomic home workstations.

The passing of the Building Safety Act 2022 very recently means that they can now establish a regulator to concentrate exclusively on the building industry. They claim this is the sector with the biggest issues and the highest number of fatalities, outside of road traffic accidents. So, it needs its own regulator that understands the issues.

Its last aim, to recruit a high-class workforce will very much be determined by the market. Every employer knows how difficult it is to recruit at present, will the HSE be able to attract and retain the necessary experts?

Laudable Goals

Alongside its stated objectives are 6 goals that they say will drive their strategy up to 2032. Their goals for the HSE are:

  • It remains relevant by keeping its regulatory framework under continual review.
  • As a fair and just regulator, it will target higher-risk activities and poorer performing employers.
  • It will be people-focused.
  • It will take a collaborative approach.
  • To remain financially viable, it will combine cost recovery and Government funding to guarantee the right level of investment.
  • It will be accessible, developing its digital capability and employing new technologies at its disposal.

These are laudable and worthy aims and make perfect sense. But the proof of the pudding is in the eating, or in the HSE’s case, in the implementation.

And, for an organisation that had never been needed more than in the pandemic, its response was disappointing. And many, including us, accused them of “going missing in action”, seemingly judging the work environment too dangerous to risk their own inspectors in the field. And, only producing relevant documentation for employers to use months after industry bodies, like IOSH, had already produced their own, that were of far better quality and practical to use than the HSE guidance.

As the saying goes, actions speak louder than words, and the HSE has had a lot of missed opportunities over the last few years. They now need to catch up if they want to still remain a credible institution, as well as being a regulatory enforcer.

 

Our consultants would be pleased to advise you on any element of the issues arising from this newsletter.

Many companies are continuing to debate hybrid working, and whether it should be introduced permanently as part of a normal way of working. Others have enthusiastically adopted it for some time.

Recent surveys by the CIPD and the IOD seem to indicate that employers are increasingly accepting that it can be a more efficient way of working and improve performance. In fact, according to the CIPD, 41% of employers in November thought this way, up from 33% a year ago. And conversely, only 18% now think it is detrimental to performance compared to 23% in 2020.

The benefits to a properly equipped, well set up, hybrid workforce is fairly self-evident. By allowing workers to split their time between the office and home, employers can not only increase efficiency, but give the individual greater flexibility, improve their work/life balance, and get away from the daily commute. So not only will this save them time and stress, but also money.

So, what is there not to like?

From a health and safety point of view, it is more complicated. For a start, the employer does not have complete control over their employee’s workplace for the whole week.

Since the start of the pandemic, with more workers working from home, there has been a significant rise in musculoskeletal disorders (MSD). Nearly all of these injuries are preventable, especially if they are associated with sitting at an inappropriately equipped and ergonomically unsound workstation for long periods of time.

In addition, if the workspace at home is not sufficiently separate and isolated from the rest of the house, then other problems can occur. The stress of working in a noisy environment, possibly with children running around, and the potential to trip over wires in a busy, crowded workspace is real.

Home working risk assessments

This should not be anything new to our regular readers. Every workspace at home should be self-risk assessed, because normally this is not possible by anyone other than the employee themselves.

However, IOSH, the professional body for Health and Safety consultants, recommends that alongside a proper risk assessment, photos and videos can be requested of the working environment to make sure it is properly set up.

We have discussed before what equipment the employer should provide, including an appropriate chair, IT equipment, phone line, broadband and the right resources, such as subscriptions and licenses, where necessary.

In addition, their Manager, or nominated health and safety competent person, should also be offering advice on how to reduce risks in the home. They should cover lighting, wiring, storage, fire, ergonomics and using a suitable workspace.

Workers should also be encouraged to look after themselves. Moving around regularly, and looking after themselves physically are essential. So, taking regular breaks looking away from the screen and being sensible about how much daily screen time they have really helps.

Post-pandemic, many employers are being faced with problems they have not really had to address up to now. Homeworking is one of them, and while many arrangements were organised in haste during the pandemic, there should now be plenty of time to review and act to make sure that everybody is working safely from home.

If not, there will be a rise in the number of claims for injuries at work and the resultant damage it has caused.

 

Our Consultants would  be pleased to advise you on any element of the issues arising from this newsletter.

The right to request flexible working was first introduced under the Employment Act 2002. In 2007, this was expanded to include caring for adult relatives. Under the Flexible Working Regulations 2014, it stopped being necessary to be a carer in order to be eligible.

In 2020, at the start of the Covid-19 pandemic, we were told to work from home wherever possible, and lo and behold millions of people found that they could do so, reasonably effectively and safely. As returning back to offices became possible once more, 2021 saw a further increase in requests, particularly people asking to work at home some or all of the time.

In theory, the penalty for employers getting it wrong is not big, i.e. up to 8 weeks’ pay at up to £571 per week, but there are other risks:

  • Raising a grievance
  • Leaving for a ‘better employer’
  • Claiming constructive unfair dismissal
  • Making a discrimination claim

The biggest risk is a discrimination claim with the scope for unlimited compensation.

There are positives to flexible working requests. The CIPD believe that flexible working has clear business benefits for organisations and individuals. Quality flexible working can help attract talent, improve employee job satisfaction and loyalty, reduce absenteeism, enhance wellbeing, and make businesses more responsive to change. There are many flexible working options for employees to choose from. Options are not limited to shorter hours or working from home (WFH). Alternatives include, staggered hours, flexitime, compressed hours, job sharing and hybrid working.

Hybrid working is where employees travel into the workplace for some of the week and work remotely for the remainder. This is likely to become more prevalent. It also has the benefit of allowing employers to save money by reducing their office space. We have seen a tendency for employers to come up with Hybrid Working policies and think this will be a sound defence if people request something different. This may help but policy is not one of the eight valid business reasons for saying no to a request for something which better suits the employee.

What to do

The first thing to do is to ensure that the employee has set out clearly what they want, and that they have documented how they think that any adverse effects to the employer can be overcome. Many employees overlook this stage, as their primary focus is ‘it’s all about them’.

It is advisable to follow the process set out in your Employee Handbook. The whole process should take less than 3 months, and in our experience, it usually takes much less. Unless an extension is agreed with the employee, you have 3 months from receipt to consider the request and issue a decision, and follow an appeal process if so requested. It is no longer necessary to do every stage within prescribed timescales, but we would always advise employers to be prompt and avoid unnecessary delays. If there are good reasons for delay, e.g. holidays, agree this with the employee and document it.

Unless you are simply accepting the request, a meeting should be arranged with the employee as soon as possible following receipt to discuss the request. After the meeting, you should send a letter to the employee setting out your decision and the right of appeal. An appeal meeting should be held as soon as possible after the appeal is lodged, and the outcome communicated as soon as possible following the meeting.

You must be able to justify your decision. A thorough factual investigation of the viability of the working pattern sought is key. You should gather as much information as possible to allow you to assess the request fully. Be wary of views such as ‘we do not have part time jobs’ or “it will set a precedent”, these are not valid responses.

Where a request cannot be agreed, think about other options that could be reached as a compromise solution. This is your chance to show that you are a reasonable employer with a ‘can-do’ approach to problem solving and compromise, which Tribunals will look favourably upon.

Conduct the meeting with a positive attitude which demonstrates the spirit of actively trying to reach an outcome that works for both of you. Be careful not to be dismissive (or to be seen to be dismissive) of the proposal from the outset. The purpose of the meeting is to explore the request with the employee and to consider all the options.

We have reproduced the ACAS Guidance on handling the meeting:

Discussing the request

You should set up a meeting to discuss the request with your employee before deciding.

It can help to talk about:

  • the change they’re asking for
  • why they want the change
  • any problems you see with making the change
  • any other options, if the change is not possible

It’s a good idea to hold the meeting somewhere private, where you can talk confidentially. If you cannot meet face to face, you could also discuss it over the phone.

If your employee wants to bring someone to the meeting

Your employee might ask to bring someone to a flexible request meeting, for example a co-worker or trade union representative.

There’s no legal right for them to bring someone, but it’s good practice to allow it.

Allowing the employee to bring someone can:

  • show your process is open and fair
  • make the meeting more relaxed
  • reduce anxiety or stress for your employee
  • give your employee someone to talk through their options with

Decide based on logic and the facts of each case avoiding the fear that you might ‘open a can of worms’. Just because you are able to agree the arrangement for one person does not mean you will be able to do so for another.

Ensure that a refusal falls within at least one of the prescribed business grounds. This needs to be clearly stated in your explanation of why the ground(s) apply. The prescribed business grounds are currently:

  1. the burden of additional costs;
  2. detrimental effect on ability to meet customer demand;
  3. inability to reorganise work among existing staff;
  4. inability to recruit additional staff;
  5. detrimental impact on quality;
  6. detrimental impact on performance;
  7. insufficiency of work during the periods the employee proposes to work; and
  8. planned structural changes;

We would recommend explaining all the relevant reasons not just reciting them.

Issues Arising

You might receive multiple requests within a team. Consider the potential impact of granting all of the requests. If this is not possible, then adopt a fair system to decide which requests are granted and which are not. It can be difficult for employers to achieve a balance and make fair decisions when managing multiple requests, especially when requests made for childcare reasons could be riskier to decline compared to those made for personal reasons. As requests can now be made for any reason, perhaps the fairest approach is to deal with the requests on a first come first served basis, and accept as many as are workable. However, it is always worth carrying out a ‘risk assessment’ to identify which (if any) are most likely to lead to claims against the organisation if refused and making your decision based on those risks.

Legislation does not specifically provide for the use of trial periods as such, but it remains open for an employer and employee to agree the terms on which any new arrangements are entered into, including that they will apply initially only for a set period of time and are subject to review. Trial periods can work for both parties because once agreed, the changes are a permanent change and the employee should not be allowed to make more than one request a year.

You should carefully monitor how well (or badly) it is working, and notify the employee of the outcome of the trial period. Issue a new or amended contract to reflect the new arrangement and the start date (or at least ensure there is a clearly documented variation to the contract). You should make it clear to the employee that this is a permanent change, and they can only request a further change after twelve months. Ideally, the employee should sign a copy of the revised contract which you can then retain in their personnel file.

The employee cannot insist on a trial period, although in appropriate cases an employee may be able to argue that an employer should have offered a trial period as part of dealing reasonably with their request. An employer may, therefore, need to consider using trial periods and be ready to explain why a trial period was not feasible in cases where it rejects a request. The length of a trial period should be no longer than required to make a fair assessment of the proposed arrangements.

It is well to remember our mantra:

It is a right to request, not a right to demand and receive

We would, however, advise clients to keep an open mind, and seek to solve the problem fairly and positively.

CIPD View

Sensible guidance from the CIPD Includes:

  1. Try to encourage a creative approach to flexible working for all employees – even in job roles that haven’t traditionally been seen as suitable for flexible working.
  2. Ensure full-time jobs are not squeezed into part-time hours.
  3. Ensure ongoing access to development and career conversations for flexible workers.
  4. Measure and evaluate flexible working, and learn from trials using quantitative and qualitative measures.
  5. Consider the facilitators and barriers at manager, team and individual levels.

In our experience, individual Managers can still be dismissive about whether flexible working ‘will work here’. They may lack experience of managing flexibility, have met difficulties with it in the past, or simply feel they have too few resources to make it work. Busy Managers may also resist any change that they think might be disruptive or add to their own workload. It is important to acknowledge such concerns. They need to be given positive suggestions for how to overcome them, and be able to point to possible benefits of trying a new approach. Just because you have had a negative one-off experience with flexible working, or lack confidence or trust in managing people more flexibly, this is not a good enough reason to refuse a request. Each application must be treated on its merits.

Except for pregnancy itself, requests are not confined to women. Employers need to remember that men can also bring flexible working requests, and you no longer have to be a carer of a child or relative to do so – it is about personal choice.

Flexible working is a hot political issue, with many demands for reform, so the Department for Business, Energy and Industrial Strategy published its consultation document on how the proposed overhaul would work in practice. There are several proposals under consultation: including making it a day one right to request flexible working; assessing whether the eight proscribed reasons are still valid; requiring employers to suggest alternatives if rejecting the request; and using flexible working on a temporary basis. Any change is unlikely to take effect quickly.

The CIPD has published new practical guidance on hybrid working, to supplement guidance recently published by ACAS on the same topic. Both publications were commissioned by the Government’s flexible working taskforce, which has recommended that flexible working should become the ‘default’ for all workers.

However, the pandemic has clearly demonstrated the opportunities offered by new ways of working. It is impossible to visualise things going back to the way they were. With roles where flexible working arrangements are possible, both employers and employees can reap the benefits – particularly around attracting and retaining diverse talent, and living up to corporate culture and values. The expectations of both employees and employers have shifted. Employers who can offer a full range of flexible working models and not just pay lip service to the statutory regime will be seen as progressive and looked on favourably by those who value these arrangements. Flexible working has now become a vital tool in attracting and retaining the best talent.

 

 

You are welcome to raise any questions with our Consultants, who will be pleased to advise you on any element of the issues arising from this newsletter.

The Pandemic has made many employers more aware than ever of the clear overlap between employment issues with health and safety practices.

As we start to gradually return to a more normal working life, employers need to be aware of what is on the changing health and safety horizon, post pandemic.

PPE Regulations

An important update to regulations concerns PPE. A term much used during the pandemic.  Personal Protective Equipment applies in many other areas, aside from protecting people from infection.

The PPE Regulations, 1992 currently require that every employer provide suitable PPE to “employees” who may be exposed to a risk to their health or safety while at work. The amended regulations mean that from April, this duty will be extended to ensure that agency and temporary workers – so-called “limb (b)” workers – are also covered by the legislation.

The definition of “worker” can be found in the Employment Rights Act 1996. The definition has two limbs, (a) and (b):

  • Limb (a) refers to those with a contract of employment. These workers are classified as employees under the Health and Safety at Work etc Act 1974, and have always been within the scope of the existing regulations.
  • Limb (b) describes workers who work under a contract for service, e.g. self-employed contractors, and casual (zero hours) workers. These individuals have not been covered by the PPE regulations up to now.

So, from 6th April, all workers will have to be provided with suitable PPE free of charge, be they casual, agency workers, subcontractors and the self-employed, if the nature of their work so requires the wearing of suitable and sufficient PPE.

The decision to extend protection to Limb (b) workers who carry out casual or irregular work, was prompted by a 2020 High Court judgment, which concluded that the UK had failed to adequately transpose aspects of two EU Directives into UK law post-Brexit. The High Court ruled that UK implementation of EU law should extend to limb (b) workers.  The HSE, after consultation, have now updated the PPE Regulations accordingly.

So, whether you work in healthcare, tree surgery, manufacturing, agriculture or any other sector where workers need protection to allow them to carry out their roles, if a worker needs protective equipment, it will be the ‘employer’s’ responsibility to make sure they have it.

What does this mean for employers?

Up to now, many employers have resisted providing these groups of workers with PPE. They have often argued, for instance, that it was up to either the agency supplying the labour to pay for the PPE, or that the agency workers themselves supply, e.g. their own safety footwear.

This is especially true if the worker could only be on site for a couple of days at most.  So, there are likely to be some interesting conversations ahead.

For most employers, the changes to the regulations will involve very little change, as most organisations will likely have already been providing PPE based on the nature of the role itself rather than the status of the person doing it.

In the case of employers who largely rely on workers – for example food delivery companies and construction companies – it will be a significant logistical and financial commitment having to now provide safety equipment to all their workers, where previously they would just have made it a condition of work that one was worn, with the worker or their firm having to supply their own.

The Highway Code

In January, the Government announced, without much fanfare, the introduction of the new Highway Code.

Many employers will have to make sure that relevant employees are briefed on the new code. Particularly if they employ drivers, and especially if they are in transport.

The changes to driver behaviour could be significant, as the new code introduces new responsibilities for drivers and road users in a strict hierarchy. Broadly speaking, the larger, the faster and more dangerous the mode of transport is to other road users and pedestrians, the more those drivers have to take care and give priority to less protected more vulnerable users.

This means that particularly in transport, large trucks and trailers present a much greater threat than vans/minibuses, and cars in turn, present a much greater threat than motorbikes and cycles.  The objective of the hierarchy is to ensure “a more mutually respectful and considerate culture of safe and effective road use that benefits all users.”

Full details of the changes in the code can be found here, and you should make sure that your drivers are aware of them.

Employer’s Liability

The issue of vicarious liability and employer responsibility is often raised in circumstances when an employee while at work, driving a business vehicle, seriously hurts, or worse still, kills others on the road, particularly a pedestrian or cyclist.  If the employer has done all that is reasonably practical to inform, instruct and train their drivers on safe driving, then that various liability can be substantially reduced.

So, it’s not enough to just send out a briefing sheet, make sure that you capture evidence that drivers have been properly informed of the new Highway Code, and they sign to understand that they are aware of, and will follow, the new hierarchy of measures. Indeed, if you wish to completely reduce vicarious liability, send your drivers on regular (typically every 3 years) advanced driver training.  Your insurance company will usually offer a discount on your premiums if you do this.

One change that has crept under the radar is that the 2022 update prohibits any driver from using their handheld device for anything, including taking videos or photos, scrolling through playlists or playing games – even if the vehicle is not moving. While mobile phones can be used for hands-free calls, payment at tolls or booths and satellite navigation, they’ll need to be securely fixed.

This update finally pulls the Code in line with the Law, banning all unnecessary – and arguably dangerous – uses of mobile phones behind the wheel. Distracted driving is the second leading cause of collisions, after drunk driving.  In line with the revised penalties introduced in 2017, motorists face a £200 fine and six penalty points, if caught touching their mobiles during their journeys. This further reinforces the need to insist that employees do not use mobile phones, and to ensure that they are not phoned from work.

Additionally, the new Highway code requires appropriate training, as these vehicles will be classed as work equipment, so the duty to ensure that drivers are competent to drive is part of the Provision and Use of Work Equipment Regulations, known as PUWER for short.

Also, part of these regulations is that employers have a duty of care to ensure that the vehicles used for business purposes, whether they are owned by the organisation or by the employee, are roadworthy, properly insured, MOT’d and serviced. They should also be checking regularly on driving licences, disqualifications and penalties, and ensuring their drivers are properly trained.

There have been calls to reverse the changes, but this is unlikely to be a successful campaign, so they are here to stay.

At BackupHR, we constantly highlight and emphasise the fact that driving is the riskiest activity we do in our day-to-day lives. Yet, because it is also regarded by most of us as a standard life skill, employers often wrongly assume that holding a driving licence is sufficient proof of competence.  In health and safety law, that is not the case, which is why making sure that your drivers are competent, safe and hold up-to-date knowledge when in front of the wheel, is essential.  Ask yourself when was the last time you looked at the most recent version of the Highway Code? It is probably the same for many of the people employed to undertake work-related driving.

Apart from the safety issues, this new set of rules will impact your business. It might not be that obvious, but fines, points and loss of driving licence can impact on an employee’s ability to perform their responsibilities.

 

 

Our Consultants would be pleased to advise you on any element of the issues arising from this newsletter.