April 2024

Miles Advisory is committed to encouraging equality, diversity and inclusion among our workforce and eliminating unlawful discrimination or harassment. We aim to create an inclusive culture, where everyone is valued and respected, where everyone has a sense of belonging with equal pay, opportunities and conditions for all.

The aim is for our workforce to be truly representative of all sections of society and our customers and for each employee to feel respected and able to give their best.

Miles Advisory, in the provision of our services is also committed against unlawful discrimination of customers, candidates, 3rd parties or the public.

The policy’s purpose is to:

• provide equality, fairness and respect for all in our employment, whether temporary, part-time or full-time
• not unlawfully discriminate because of the Equality Act 2010 protected
• characteristics of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality and ethnic or national origin), religion or belief, sex and sexual orientation
• oppose and avoid all forms of unlawful discrimination. This includes in pay and benefits, terms and conditions of employment, dealing with grievances and discipline, dismissal, redundancy, leave for parents, requests for flexible working and selection for employment, promotion, training or other developmental opportunities.

Miles Advisory commits to:

• encourage equality, diversity and inclusion in the workplace as they are good practice and make business sense
• create a working environment free of bullying, harassment, victimisation and unlawful discrimination, promoting dignity and respect for all, where individual differences and contributions of all staff are recognised and valued

This commitment includes training managers and all other employees about their rights and responsibilities under the equality, diversity and inclusion policy. Responsibilities include staff conducting themselves to help the organisation provide equal opportunities in employment and prevent bullying, harassment, victimisation and unlawful discrimination

All staff should understand they, as well as their employer, can be held liable for acts of bullying, harassment, victimisation and unlawful discrimination, in the course of their employment, against fellow employees, customers, suppliers, other 3rd parties and the public

Take seriously complaints of bullying, harassment, victimisation and unlawful discrimination by fellow employees, customers, suppliers, visitors, the public and any others in the course of the organisation’s work activities.

April 2024

Policy brief & purpose

Our Corporate Social Responsibility (CSR) company policy refers to our responsibility toward our environment. We are part of a bigger system of people, values, other organisations and the natural environment. The social responsibility of a business is to give back to the world just as it gives to us.

What is corporate social responsibility?

Our Corporate Social Responsibility (CSR) company policy outlines our efforts to give back to the world as it gives to us.

Scope

This policy applies to our company and its subsidiaries. It may also refer to suppliers and partners.

Policy elements

We want to be a responsible business that meets the highest standards of ethics and professionalism.

Miles Advisory’s social responsibility falls under two categories: compliance and proactiveness. Compliance refers to our company’s commitment to legality and willingness to observe community values. Proactiveness is every initiative to promote human rights, help communities and protect our natural environment, whether working from an office or home.

Compliance and legality

Miles Advisory will:

• Respect the law
• Honour our internal policies
• Ensure that all our business operations are legitimate
• Keep every partnership and collaboration open and transparent
• Business ethics

We will always conduct business with integrity and respect to human rights. We will promote:

• Safety and fair dealing
• Respect toward the consumer
• Anti-bribery and anti-corruption practices

Protecting the environment

Our company recognises the need to protect the natural environment. Keeping our environment clean and unpolluted is a benefit to all. We will always follow best practices when disposing of waste and using chemical substances. Stewardship will also play an important role.

Protecting people

We will ensure that we:

• Do not risk the health and safety of our employees and community  Avoid harming the lives of local and indigenous people
• Support diversity and inclusion

Human rights

Our company is dedicated to protecting human rights. We are a committed equal opportunity employer and will abide by all fair employment practices. We will ensure that our activities do not directly or indirectly violate human rights in any country (e.g. forced labour).

Donations and Fundraising

Miles Advisory may preserve a budget or undertake fundraising activities to make monetary donations. These donations will aim to:

• Advance the arts, education and community events.
• Alleviate those in need.

Volunteering

Miles Advisory will encourage its employees to volunteer. They can volunteer through programmes organised internally or externally. Miles Advisory may sponsor volunteering events from other organisations.

Preserving the environment

Apart from legal obligations, Miles Advisory will proactively protect the environment whether its employees are working from our offices or home. Examples of relevant activities include:

Recycling

• Conserving energy
• Using environmentally-friendly technologies
• Minimising travel

Supporting the community

Miles Advisory may initiate and support community investment and educational programs. For example, it may begin partnerships with schools or care institutions. It can provide support to non-profit organisations or movements to promote cultural and economic development of global and local communities.

Learning

We will actively invest in L&D. We will be open to suggestions and listen carefully to ideas. Miles Advisory will try to continuously improve the way it operates.

Responsibility

We will readily act to promote our identity as a socially aware and responsible business. Management must communicate this policy on all levels. Managers are also responsible for resolving any CSR issues.

April 2024

The Board and management are committed to enforcing effective systems and controls to ensure modern slavery is not taking place anywhere within our own business or in any of our supply chains.

Modern Slavery encompasses all acts of slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. Miles Advisory has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships.

We employ mainly highly skilled professional and administrative staff and as such is at low risk of modern slavery and human trafficking. All employees are provided with a clear contract of employment, which complies with UK legislation. Employees are treated in a fair and equal manner and with dignity and respect. We do not tolerate any form of discrimination, victimisation or harassment on any grounds. New employees are made aware of our ethical and compliance standards and as part of this process they are made aware how to report and deal with such an instance. Our whistleblowing policy supports and encourages our staff to report wrongdoing and this extends to Modern Slavery.

We are also committed to act ethically, with integrity and transparency in all our business dealings and relationships. We communicate our zero-tolerance view of modern slavery to all suppliers and outsourcing partners at the start of our business relationship. We will terminate our relationship with third parties if they do not comply with this policy. We have not identified any specific risk areas within our supply chain but as a matter of good practice, we monitor and mitigate any actual or potential risks and where necessary, take steps to strengthen these contractual relationships. Our Modern Slavery best practice is reviewed annually.

Miles Advisory are registered with the Information Commissioner’s Office and follow their principals:

• Lawfulness, fairness and transparency  Purpose limitation
• Data minimisation
• Accuracy
• Storage limitation
• Integrity and confidentiality (security)  Accountability

This policy:

• sets out the types of personal data that we collect about you   explains how and why we collect and use your personal data  explains how long we keep your personal data for
• explains when, why and with who we will share your personal data  sets out the legal basis we have for using your personal data
• explains the effect of refusing to provide the personal data requested
• explains the different rights and choices you have when it comes to your personal data
• explains how we may contact you and how you can contact us.

What personal data do we collect about you?

Candidates: We collect the information necessary to be able to identify appropriate opportunities for you and also any further information needed to assess your eligibility through the different stages of the recruitment process. This information may include, identification and visa documents, CVs and work history, photographs, contact details, educational records and checks, psychometric assessments, salary data, employment references, commentary on fit to role and, where applicable, commentary on progress in role once placed. When requested by a client, we may collect equal opportunity information

Clients: contact details, details shared on the client organisation

Where do we collect personal data about you from?

The following are the different sources we may collect personal data about you from:

Directly from you. This is information you provide while searching for a new opportunity and/or during the different recruitment stages as client and/or candidate. This may be in hard copy, electronically by email, during conversations or interview, or entered into the application section of our microsite

By reference or word of mouth. For example, you may be recommended by a friend, a former employer, a former colleague or even a present employer.

• Through publicly available sources. We use the following public sources:
• LinkedIn
• Company websites  WorldWide Web

How and why do we use your personal data?

We use your personal data to match your skills, experience and education with a potential employer. We will initially collect basic information on you such as contact details, job role and experience and pass this on to client with relevant requirements. If you are suitably qualified and interested in proceeding, we will, with your agreement, collect more information from you as you progress through the process e.g. to our interview stage and then to client interview stage.

Equal opportunities information is used to provide diversity statistics on recruitment campaigns when contractually obliged to do so by a client. This data is always anonymised. We recognised this is sensitive personal data and requires stricter data protection

How long do we keep your personal data for?

We keep your information in accordance with our data retention policy as follows:

• Candidate data: 7 years
• Client contact details: 7 years
• Equal Opportunities – this is deleted at the end of each campaign for which it is required

Who do we share your personal data with?

Your personal data is shared with the client who initiates a search for personnel, to ascertain whether you might be a fit for the position. We may also conduct checks on you to verify the information you have provided

What legal basis do we have for using your information?

For prospective candidates, referees and clients, our processing is necessary for our legitimate interests in that we need the information in order to be able to assess suitability for potential roles, to find potential candidates and to contact clients and referees.

For clients, we may also rely on our processing being necessary to enabling us to fulfil a contractual obligation to you.

Equal opportunities data is only used with consent and for the limited purpose of required client reporting (anonymised)

What happens if you do not provide us with the information we request or ask that we stop processing your information?

If you do not provide the personal data necessary, or request that we stop processing your personal data, we may not be able to match you with available job and career opportunities.

Do we make automated decisions concerning you?

No, we do not carry out automated profiling.

Do we transfer your data outside the EEA?

To better match your employee profile with current opportunities we may transfer your personal data to clients and partners in countries outside the EEA. These countries’ privacy laws may be different from those in your home country. Where we transfer data to a country which has not been deemed to provide adequate data protection standards we always have security measures and approved model clauses in place to protect your personal data. To find out more about how we safeguard your information as related to transfers contact us on privacy@miles-advisory.com

What rights do you have in relation to the data we hold on you?

 Under the Data Protection legislation, data subjects have the following rights with regards to their personal information:

• the right to be informed about the collection and the use of their personal data  the right to access personal data and supplementary information
• the right to have inaccurate personal data rectified, or completed if it is  incomplete
• the right to erasure (to be forgotten) in certain circumstances  the right to restrict processing in certain circumstances
• the right to data portability, which allows the data subject to obtain and reuse their personal data for their own purposes across different services
• the right to object to processing in certain circumstances
• rights in relation to automated decision making and profiling  the right to withdraw consent at any time (where relevant)
• the right to complain to the Information Commissioner

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

• baseless or excessive/repeated requests, or  further copies of the same information.

Alternatively, we may be entitled to refuse to act on the request.

Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.

How will we contact you?

We may contact you by phone, email or social media. If you prefer a particular contact means over another, please just let us know.

How can you contact us?

If you are unhappy with how we’ve handled your information, or have further questions on the processing of your personal data, contact our Data Protection Officer here:

Tina Stainton TMP Advisory. 5-7 St Paul’s St, Leeds, LS1 2JG Email: tina.stainton@miles-advisory.com