Freedom of Association and Collective Bargaining Policy

1. Purpose and Scope

i. Purpose

This policy outlines Solapave's commitment to respecting and promoting the rights of our employees to freedom of association and collective bargaining within the United Kingdom. It establishes the regular processes and management approach we use to ensure these rights are protected and upheld throughout our UK operations, in compliance with UK labour laws and regulations.

ii. Scope

This policy applies to all Solapave operations, including all employees, workers (as defined by the Employment Rights Act 1996), and contractors. We also expect our suppliers and business partners to adhere to similar principles.

2. Policy Statement

Solapave recognises and respects the rights of employees to freedom of association and collective bargaining as fundamental rights protected under UK law, including the Trade Union and Labour Relations (Consolidation) Act 1992. We are committed to maintaining an open and collaborative relationship with our employees and their chosen representatives, and to negotiating in good faith in accordance with UK labour regulations.

3. Definitions

i. Freedom of Association: The right of workers to join or form trade unions or other worker organisations of their own choosing without prior authorisation or interference, as protected by UK law.

ii. Collective Bargaining: The process of negotiations between employers and a group of employees (usually represented by a trade union) aimed at reaching agreements that regulate working conditions, as outlined in the Trade Union and Labour Relations (Consolidation) Act 1992.

4. Management Approach and Regular Processes

i. Neutrality Commitment

• We maintain a position of neutrality regarding employees' decisions to join or not join a trade union, in accordance with the Employment Relations Act 1999.

• Management is prohibited from interfering with, restraining, or coercing employees in the exercise of their rights to freedom of association.

ii. Open Communication Channels

• Regular town hall meetings where employees can raise concerns or questions about labour rights.

• An open-door policy allowing employees to discuss association and bargaining matters with management.

• A confidential whistleblowing hotline for reporting any violations of freedom of association rights, in compliance with the Public Interest Disclosure Act 1998.

iii. Employee Education and Awareness

• Annual training sessions for all employees on their rights to freedom of association and collective bargaining under UK law.

• Information on these rights included in employee handbooks and onboarding materials, referencing relevant UK legislation.

• Regular communications reinforcing the company's commitment to these rights and explaining the role of trade unions in the UK context.

iv. Management Training

• Mandatory annual training for all managers and supervisors on respecting freedom of association and collective bargaining rights in accordance with UK labour laws.

• Specific training on UK labour relations and negotiation skills for relevant management personnel.

v. Due Diligence Process

• Annual assessment of risks to freedom of association and collective bargaining rights in all our UK operations.

• Integration of these rights into our broader human rights due diligence processes, aligned with the UK Modern Slavery Act 2015.

vi. Grievance Mechanism

• A formal grievance mechanism allowing employees to report any violations of their association or bargaining rights, in line with the ACAS Code of Practice on disciplinary and grievance procedures.

• Clear procedures for investigating and resolving such grievances in a timely manner.

vii. Collective Bargaining Process

• Established procedures for recognising trade unions, including voluntary recognition and the statutory recognition process as outlined in the Trade Union and Labour Relations (Consolidation) Act 1992.

• Commitment to negotiate in good faith with recognised trade unions or employee representatives.

• Regular review of collective bargaining agreements to ensure compliance with UK employment law.

viii. Supplier and Business Partner Engagement

• Inclusion of freedom of association and collective bargaining rights in our Supplier Code of Conduct, with specific reference to UK labour standards.

• Regular audits of key UK suppliers to ensure compliance with these rights.

• Capacity-building programmes to help suppliers improve their practices in this area, with a focus on UK labour relations.

ix. Neutrality During Organisation Efforts

• Clear guidelines for management behaviour during union organising campaigns to ensure neutrality and compliance with UK labour laws.

• Provision of equal access to information for all parties during organisation efforts, in line with the Code of Practice on Access to Workers During Recognition and Derecognition Ballots.

x. Regular Stakeholder Engagement

• Annual meetings with trade union representatives (where applicable) to discuss labour relations issues.

• Engagement with UK labour rights organisations and relevant government bodies (e.g., ACAS) to stay informed of best practices and potential issues.

xi. Monitoring and Reporting

• Key Performance Indicators (KPIs) established to measure our performance in upholding these rights in the UK context.

• Quarterly internal reviews of our performance against these KPIs.

• Annual public reporting on our efforts to uphold freedom of association and collective bargaining rights in our UK operations.

xii. Third-Party Audits

• Regular third-party audits of our practices related to freedom of association and collective bargaining, conducted by UK-based labour experts.

• Public disclosure of audit results and corrective action plans.

xiii. Continuous Improvement Process

• Annual review of this policy and related procedures to ensure ongoing compliance with UK labour laws and best practices.

• Incorporation of lessons learned and best practices into our approach, considering guidance from bodies such as ACAS and the Equality and Human Rights Commission.

5. Responsibilities

i. Directors: Oversee the company's approach to freedom of association and collective bargaining.

ii. CEO and Executive Team: Ensure resources are available to implement this policy effectively across UK operations.

iii. Human Resources Department:

• Implement and manage the processes outlined in this policy in compliance with UK labour laws.

• Provide guidance to managers and employees on freedom of association matters within the UK legal framework.

• Lead collective bargaining processes where applicable, ensuring compliance with UK regulations.

iv. Legal Department: Provide guidance on legal aspects of freedom of association and collective bargaining under UK law.

v. All Managers:

• Uphold and promote the principles outlined in this policy.

• Ensure their teams are aware of and respect these rights within the UK context.

i. All Employees:

• Familiarise themselves with their rights as outlined in this policy and under UK law.

• Report any suspected violations of these rights through appropriate channels.

6. Non-Retaliation

Solapave strictly prohibits any form of retaliation against employees for exercising their rights to freedom of association or collective bargaining, or for reporting suspected violations of these rights, in accordance with UK whistleblowing protections.

7. Policy Review

This policy will be reviewed annually and updated as necessary to reflect changes in UK law, best practices, or business circumstances.

8. Communication of Policy

This policy will be communicated to all UK employees through:

• Company-wide emails

• Posting on company intranet and physical notice boards

• Inclusion in employee handbooks

• Discussion in relevant training sessions

It will also be made publicly available on our UK corporate website.

By implementing this policy and the processes outlined within it, Solapave demonstrates its ongoing commitment to upholding the fundamental labour rights of freedom of association and collective bargaining in accordance with UK law and best practices.