DATA PROTECTION POLICY

A. INTRODUCTION

We may have to collect and use information about people with whom we work.  This personal information must be handled and dealt with properly, however it is collected, recorded and used, and whether it be on paper, in computer records or recorded by any other means.

We regard the lawful and correct treatment of personal information as very important to our successful operation and to maintaining confidence between us and those with whom we carry out business.  We will ensure that we treat personal information lawfully and correctly.

To this end we fully endorse and adhere to the principles of the General Data Protection Regulation (GDPR).

This policy applies to the processing of personal data in manual and electronic records kept by us in connection with our human resources function as described below. It also covers our response to any data breach and other rights under the GDPR.

This policy applies to the personal data of job applicants, existing and former employees, apprentices, volunteers, placement students, workers and self-employed contractors. These are referred to in this policy as relevant individuals.

B. DEFINITIONS

“Personal data” is information that relates to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier. It can also include pseudonymised data.

“Special categories of personal data” is data which relates to an individual’s health, sex life, sexual orientation, race, ethnic origin, political opinion, religion, and trade union membership. It also includes genetic and biometric data (where used for ID purposes).

“Criminal offence data” is data which relates to an individual’s criminal convictions and offences.

“Data processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

C. DATA PROTECTION PRINCIPLES

Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:

1. processing will be fair, lawful and transparent
2. data be collected for specific, explicit, and legitimate purposes
3. data collected will be adequate, relevant and limited to what is necessary for the purposes of processing
4. data will be kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
5. data is not kept for longer than is necessary for its given purpose
6. data will be processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures
7. we will comply with the relevant GDPR procedures for international transferring of personal data

D. TYPES OF DATA HELD

We keep several categories of personal data on our employees in order to carry out effective and efficient processes. We keep this data in a personnel file relating to each employee and we also hold the data within our computer systems, for example, our holiday booking system.

Specifically, we hold the following types of data:

1. personal details such as name, address, phone numbers
2. information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter, references from former employers, details on your education and employment history etc
3. details relating to pay administration such as National Insurance numbers, bank account details and tax codes
4. medical or health information
5. information relating to your employment with us, including:
   1. job title and job descriptions
   2. your salary
   3. your wider terms and conditions of employment
   4. details of formal and informal proceedings involving you such as letters of concern, disciplinary and grievance proceedings, your annual leave records, appraisal and performance information
   5. internal and external training modules undertaken

All of the above information is required for our processing activities. More information on those processing activities are included in our privacy notice for employees, which is available from your manager.

E. EMPLOYEE RIGHTS

You have the following rights in relation to the personal data we hold on you:

1. the right to be informed about the data we hold on you and what we do with it;
2. the right of access to the data we hold on you. More information on this can be found in the section headed “Access to Data” below and in our separate policy on Subject Access Requests”;
3. the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
4. the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
5. the right to restrict the processing of the data;
6. the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
7. the right to object to the inclusion of any information;
8. the right to regulate any automated decision-making and profiling of personal data.

More information can be found on each of these rights in our separate policy on employee rights under GDPR.

F. RESPONSIBILITIES

In order to protect the personal data of relevant individuals, those within our business who must process data as part of their role have been made aware of our policies on data protection.

We have also appointed employees with responsibility for reviewing and auditing our data protection systems.

G. LAWFUL BASES OF PROCESSING

We acknowledge that processing may be only be carried out where a lawful basis for that processing exists and we have assigned a lawful basis against each processing activity.

Where no other lawful basis applies, we may seek to rely on the employee’s consent in order to process data.

However, we recognise the high standard attached to its use. We understand that consent must be freely given, specific, informed and unambiguous. Where consent is to be sought, we will do so on a specific and individual basis where appropriate. Employees will be given clear instructions on the desired processing activity, informed of the consequences of their consent and of their clear right to withdraw consent at any time.

H. ACCESS TO DATA

As stated above, employees have a right to access the personal data that we hold on them. To exercise this right, employees should make a Subject Access Request. We will comply with the request without delay, and within one month unless, in accordance with legislation, we decide that an extension is required. Those who make a request will be kept fully informed of any decision to extend the time limit.

No charge will be made for complying with a request unless the request is manifestly unfounded, excessive or repetitive, or unless a request is made for duplicate copies to be provided to parties other than the employee making the request. In these circumstances, a reasonable charge will be applied.

Further information on making a subject access request is contained in our Subject Access Request policy.

I. DATA DISCLOSURES

The Company may be required to disclose certain data/information to any person. The circumstances leading to such disclosures include:

1. any employee benefits operated by third parties;
2. disabled individuals – whether any reasonable adjustments are required to assist them at work;
3. individuals’ health data – to comply with health and safety or occupational health obligations towards the employee;
4. for Statutory Sick Pay purposes;
5. HR management and administration – to consider how an individual’s health affects his or her ability to do their job;
6. the smooth operation of any employee insurance policies or pension plans;
7. to assist law enforcement or a relevant authority to prevent or detect crime or prosecute offenders or to assess or collect any tax or duty.

These kinds of disclosures will only be made when strictly necessary for the purpose.

J. DATA SECURITY

All our employees are aware that hard copy personal information should be kept in a locked filing cabinet, drawer, or safe.

Employees are aware of their roles and responsibilities when their role involves the processing of data.  All employees are instructed to store files or written information of a confidential nature in a secure manner so that it is only accessible by people who have a need and a right to access them and to ensure that all PCs, laptops etc are secured when unattended. No files or written information of a confidential nature is to be left where it can be accessed by unauthorised people.

Where data is computerised, it should be coded, encrypted or password protected both on a local hard drive and on a network drive that is regularly backed up. If a copy is kept on removable storage media, that media must itself be kept in a locked filing cabinet, drawer, or safe.

Employees must always use the passwords provided to access the computer system and not abuse them by passing them on to people who should not have them.

Personal data relating to employees should not be kept or transported on laptops, USB sticks, or similar devices, unless prior authorisation has been received. Where personal data is recorded on any such device it should be protected by:

1. ensuring that data is recorded on such devices only where absolutely necessary.
2. using an encrypted system — a folder should be created to store the files that need extra protection and all files created or moved to this folder should be automatically encrypted.
3. ensuring that laptops or USB drives are not left where they can be stolen.

Failure to follow the Company’s rules on data security may be dealt with via the Company’s disciplinary procedure. Appropriate sanctions include dismissal with or without notice dependent on the severity of the failure.

K. THIRD PARTY PROCESSING

Where we engage third parties to process data on our behalf, we will ensure, via a data processing agreement with the third party, that the third party takes such measures in order to maintain the Company’s commitment to protecting data.

L. INTERNATIONAL DATA TRANSFERS

The Company does not transfer personal data to any recipients outside of the EEA.

M. REQUIREMENT TO NOTIFY BREACHES

All data breaches will be recorded on our Data Breach Register. Where legally required, we will report a breach to the Information Commissioner within 72 hours of discovery. In addition, where legally required, we will inform the individual whose data was subject to breach.

More information on breach notification is available in our Breach Notification policy.

N. TRAINING

New employees must read and understand the policies on data protection as part of their induction.

All employees receive training covering basic information about confidentiality, data protection and the actions to take upon identifying a potential data breach.

The nominated data controller/auditors/protection officers for the Company are trained appropriately in their roles under the GDPR.

All employees who need to use the computer system are trained to protect individuals’ private data, to ensure data security, and to understand the consequences to them as individuals and the Company of any potential lapses and breaches of the Company’s policies and procedures.

O. RECORDS

The Company keeps records of its processing activities including the purpose for the processing and retention periods in its HR Data Record. These records will be kept up to date so that they reflect current processing activities.

P. DATA PROTECTION COMPLIANCE

Our Data Protection Officer is:

Patrick O’Gorman
dpo@bcegi.co.uk
+44 (0) 746 748 1311

HEALTH AND SAFETY

STATEMENT OF INTENT

BCEGI is committed to eliminating incidents of injury and ill health to its employees and any other stakeholders affected by its activities. As part of this duty BCEGI will operate its business in compliance with its obligations under all applicable health and safety Regulations and – where appropriate – best practice standards and industry codes relevant to its operations.

In support of this commitment BCEGI will provide a safe place of work for its people, ensuring that all risks arising out of its business activities are identified and hazards are effectively controlled by following the hierarchy of controls for occupational health and safety. This includes providing instruction and training to its people to enable work to be carried out safely, and without ill health effects. BCEGI are committed to consultation with and participation of workers on health and safety matters.

RESPONSIBILITIES

Responsibility for this Policy ultimately lies with the BCEGI Lead Director, supported by the Management Team and SHEQ Lead who are responsible for the implementation of the Policy Statement and all associated Management Standards. The Management Team – supported by Project Managers – must at all times demonstrate proactive and visible leadership in relation to health and safety management, and are responsible for communicating BCEGI health and safety objectives throughout the organisation, and for ensuring that effective arrangements are in place and effective at a Project level. This Policy and associated Management Standards are mandatory across all BCEGI operations and as such all BCEGI Employees and Stakeholders are expected to comply with all related arrangements.

ARRANGEMENTS

Arrangements for the management of Health and Safety are contained within the BCEGI Integrated Management System (IMS), and are made available to all employees, supply chain partners and affected parties. This policy is subject to continual review to ensure that it remains relevant to the scope of BCEGI operations and to account for changes in its working practices.

AUTHORISATION

Dongwen Yu
Lead Director
5^th February 2021

Archive: 2020 Health and Safety Policy
2019 Health and Safety Policy
2018 Health and Safety Policy
2017 Health and Safety Policy
2016 Health and Safety Policy

ENVIRONMENT

STATEMENT OF INTENT

BCEGI recognises the importance of minimising the impact of its activities on the environment and is committed to eliminating incidents of pollution whilst continually reducing the environmental footprint associated with delivering its business operations. As part of this duty BCEGI will operate its business in compliance with its obligations under all applicable environmental Regulations and – where appropriate – relevant best practice standards and industry codes.

In support of this commitment BCEGI will routinely evaluate its environmental aspects and impacts in order to reduce the waste it produces and energy it consumes, whilst protecting the natural environment at its project and office locations and promoting the use of sustainable materials and technologies throughout its supply chain. This includes providing instruction and training to its people to enable work to be carried out sustainably, and without adverse impacts on the environment.

RESPONSIBILITIES

Responsibility for this Policy ultimately lies with the BCEGI Lead Director, supported by the Management Team and SHEQ Lead who are responsible for the implementation of the Policy Statement and all associated Management Standards. The Management Team – supported by Project Managers – must at all times demonstrate proactive and visible leadership in relation to environmental management and are responsible for communicating BCEGI environmental objectives throughout the organisation, whilst ensuring that effective arrangements are in place at a Project level. This Policy and associated Management Standards are mandatory across all BCEGI operations and as such all BCEGI Employees and Stakeholders are expected to comply with all related arrangements.

ARRANGEMENTS

Arrangements for the management of its environmental aspects are contained within the BCEGI Integrated Management System (IMS), and are made available to all employees, supply chain partners and affected parties. This policy is subject to continual review to ensure that it remains relevant to the scope of BCEGI operations and to account for changes in its working practices.

AUTHORISATION

Dongwen Yu
Lead Director
5^th February 2021

Archive: 2020 Environmental Policy
2019 Environmental Policy
2018 Environmental Policy
2017 Environmental Policy

QUALITY MANAGEMENT

STATEMENT OF INTENT

BCEGI’s mission is to exceed expectations in all aspects of its construction, development and investment activities, and in doing so aims to be recognised as the trusted partner for all its clients and stakeholders. In order to achieve this aim BCEGI is committed to providing its Customers with defect-free products and services, delivered on time and within budget, and has implemented an organisation-wide Integrated Management System (iMS) which – as a minimum – complies with relevant statutory legislation, industry best practice, stakeholder needs, and the requirements of BS EN ISO9001:2015.

RESPONSIBILITIES

Responsibility for establishing this Policy ultimately lies with the BCEGI Lead Director who will ensure that suitable resources are in place to enable compliance with relevant Company standards and Customer requirements. The BCEGI Management Team – supported by the SHEQ Lead – are responsible for the continual review of BCEGI Company performance, the provision of appropriate organisational context and the setting of strategic direction, and for providing a framework for setting quality objectives that enhance BCEGI Customer satisfaction. The Management Team – supported by Project Managers – must at all times demonstrate proactive and visible leadership in relation to quality management and are responsible for communicating BCEGI quality objectives throughout the organisation, and for ensuring that effective arrangements are in place and effective at a Project level. This Policy and associated Management Standards are mandatory across all BCEGI operations and as such all BCEGI Employees are expected to comply with all related arrangements.

ARRANGEMENTS

Arrangements for the management of Quality are contained within the BCEGI Integrated Management System (iMS), including controls to ensure the continual monitoring of quality performance across the organisation, and the ongoing review of the effectiveness and suitability of quality management measures within the iMS.

AUTHORISATION

Dongwen Yu
Lead Director
5^th February 2021

Archive: 2020 Quality Policy
2019 Quality Policy
2018 Quality Policy
2017 Quality Policy

MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

This statement has been published in accordance with the Modern Slavery Act 2015 and sets out the steps BCEGI UK has taken to prevent human trafficking and slavery in our business and supply chain.

BCEGI UK is committed to promoting ethical business practices and policies to protect its workers, and those who work with the Company. We are dedicated to acting transparently by disclosing information about any modern slavery risks we may identify and what actions we will take in response to them – prioritising any risks as they arise and making year-on-year progress to improve our processes.

BCEGI’s Directors and Senior Management shall take responsibility for implementing and communicating this Policy Statement and its objectives and shall provide adequate resources (awareness, training, etc.) and investment to ensure that modern slavery and human trafficking is not taking place within the organisation or its supply chains.

A copy of this Policy Statement is available to all employees electronically and can be obtained from the HR department upon request. This Policy Statement will be reviewed annually.

OUR BUSINESS AND SUPPLY CHAINS

BCEGI was founded in the UK in 2013 as part of BCEG’s international expansion scheme. BCEG was founded in China in 1953 and is a major Chinese state-owned enterprise, which works in over 27 countries globally. As an internationally diverse business, we draw on a wide range of knowledge and skills from different backgrounds across the globe.

Our strength and depth of cultural, personal and professional understanding means we are well placed to successfully facilitate and deliver bi-lateral trade, particularly between the East and West. BCEGI are key members of the Manchester China Forum, we are proud ambassadors for Manchester and the North West and are proactively operating as a first point of contact for international businesses wishing to invest in the UK and Europe.

Our mission at BCEGI is to exceed expectations in all aspects of our construction, development and investment activities. We aim to be the trusted partner for all our clients and stakeholders.

Our Supply Chain contains a range of companies, from large scale sub-contractors and professional consultants, to small supply only companies used for one off purchases. Our Supply Chain plays a pivotal role in BCEGI’s ability to successfully deliver its developments / projects in line with our own and / or our Employers expectations. We are constantly reviewing our Supply Chain members to ensure they continually meet the requirements of BCEGI. This includes a stringent Pre-Qualifications Questionnaire process and ongoing review of our Supply Chain partners.

OUR POLICIES

We have a zero-tolerance approach towards modern slavery and human trafficking, which is implemented into our Policies and behaviours within the workplace and supply chain.

This Policy Statement will be reviewed and updated annually and will be published on our website (with historical versions also available). Our policies are communicated to all employees through our intranet, inductions, training and briefings. We expect our supply chain to follow similar practices to ensure compliance and consistency.

We continually review our Policies, commercial agreements, consultant appointments and supply of services to reflect our commitment to acting sustainably, ethically and with integrity in all our business relationships. We are also in the process of reviewing and populating our Supplier Code of Conduct to improve our risk management processes.

The following Policies are relevant to Modern Slavery and Human Trafficking:

• Our Modern Slavery and Human Trafficking Policy specifically sets out our zero-tolerance for any activities related to slavery, how we create further awareness and what measures we have in place to prevent this.
• Our Code of Conduct sets out our expectations, such as rejecting anti-bribery and corruption and compliance with the law.

OUR CORE VALUES

Our Core Values are at the heart of everything we do. Our Board of Directors drive them alongside Senior Managers to embed our Core Values, and to create an efficient and positive working environment for our people, supply chains and the communities in which we work.

DUE DILIGENCE PROCESSES

Within our own business

Wherever possible we directly recruit our employees. We do however utilise the use of agencies where necessary. When sourcing and placing candidates with us, Our Preferred Supplier List must comply with the Act and ensure they have up-to-date Processes in place to manage any risks associated with the Act.

We always verify the Right to Work of all our employees and ensure their salary is paid directly to them.

Supply chain

BCEGI acknowledges its responsibility to the Modern Slavery Act 2015 and will ensure transparency within BCEGI and with suppliers of goods and services to the organisation. These, as well as the suppliers of services, make up the supply chain within the Company.

As part of BCEGI’s due diligence processes into modern slavery and human trafficking, the supplier approval process incorporates a review of the controls undertaken by its suppliers.

Imported goods from sources from outside the UK and EU are potentially more at risk for modern slavery and human trafficking issues. The level of management control required for these sources will be continually monitored.

BCEGI will not support or deal with any business knowingly involved in modern slavery or human trafficking.

RISK ASSESSMENT AND MANAGEMENT

We have or are in the process of creating the following:

• Our current suppliers are asked to conform with this Policy Statement and our Supplier Code of Conduct, where non-conformance may result in supplier auditing and/or termination of agreement.
• All employees are made aware of our commitment to combatting modern slavery and human trafficking.
• Training of our Senior Management Team and employees involved in the procurement process.
• Introduction of modern slavery awareness training during company induction and periodically for current relevant employees.
• Internal audit programme to review Policy content and use.
• Evidence of right to work is required before official employment can commence.
• Salary of both new and existing employees can only be paid to a bank account owned and controlled by the employee.

AWARENESS AND TRAINING

We create awareness on modern slavery and human trafficking via updating this Policy Statement annually and ensuring it is available for employees to review via our iMS and for the general public via our website. This is something existing and new employees are encouraged to review upon starting with us and throughout employment.

Our Whistleblowing Policy encourages employees to report any unethical practices either internally or externally within the business or via our suppliers. Any reports received are taken extremely seriously and are fully investigated.

AUTHORISATION

Dongwen Yu

Lead Director

1^st January 2022

Archive:
2020 Modern Slavery and Human Trafficking Policy
2019 Modern Slavery and Human Trafficking Policy
2018 Modern Slavery Policy
2017 Modern Slavery Policy

COOKIES POLICY

About this cookie policy

This Cookie Policy explains what cookies are and how we use them. Please make sure you read this policy so you can understand what types of cookies we use, how we collect and use information from and about you.

What are cookies?

Cookies are small text files that are sent to your PC, mobile phone or tablet when you visit a website. They stay on your device and are sent back to the website they came from when you visit it again.

Cookies are used by BCEGI website to make your experience more efficient by:

• Recognising when you log in and any preferred settings.
• Giving you a browsing experience that is unique to you which we believe improves your site experience.
• Analysing how you use our website and our services, so we can improve them.

How do we use cookies?

We and third parties may use cookies and tracking technologies to collect information from websites, Applications, and other online services for a variety of reasons, such as to enable us to improve your experience of the services, to understand how users interact with our online services and advertisements, and to deliver advertising. For example, we use these technologies to allow us to know when and for how long you use our services, and to remember your preferences and settings and other functionality you have requested. We and third parties may use the technologies to link your activities across the devices you may use. This helps us learn about how you use the services and enables us to provide you with a seamless experience across your devices. We may also use cookies and tracking technologies to deliver advertising and marketing messages that we think may be relevant to you based on your online activities over time, across the various devices you may use, and across third-party services– a common practice across the internet and known as interest-based advertising or behavioral advertising.

More information about analytics and advertising cookies is detailed below.

1. Strictly Necessary Cookies

These cookies enable services you have specifically asked for. For those types of cookies that are strictly necessary, no consent is required. These cookies are essential in order to enable you to move around the Website and use it features, such as accessing secure areas of the Website. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided.

2. Performance Cookies

These cookies collect information about how you use our websites — for instance, which pages you go to most. This data may be used to help optimize our websites and make them easier for you to navigate. These cookies are also used to let affiliates know if you came to one of our websites from an affiliate and if your visit resulted in the use or purchase of a product or service from us, including details of the product or service purchased. These cookies don’t collect information that identifies you. All information these cookies collect is aggregated and therefore anonymous.

3. Functionality Cookies

These cookies allow our websites to remember choices you make while browsing. For instance, we may store your geographic location in a cookie to ensure that we show you our website localized for your area. We may also remember preferences such as text size, fonts, and other customizable site elements. They may also be used to keep track of what featured products or videos have been viewed to avoid repetition. The information these cookies collect will not personally identify you, and they cannot track your browsing activity on non-BCEGI websites.

4. Third Party Cookies

This website uses a number of supplies who also set cookies on our website on our behalf in order to deliver the services that they are providing. A list of all third party cookies that are used on this Website and what each is used for are YouTube and Fusion Theme.

We use the following cookies on our site:

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Google Maps Cookies	APISID	These cookies are used by Google to store user preferences and information of Google maps
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YouTube Cookies	PREF	We embed videos from YouTube on our website. These cookies do not identify you personally unless you are logged into Google, in which case it is linked to your Google account. They are used to measure your bandwidth when you watch a video in order to adjust video settings accordingly, or to track and gather information about when you watch YouTube videos on different websites.
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How do you change cookie preferences or block cookies?

We provide multiple choices in respect of the information we process about you. You can choose to opt-out, object to, or restrict our use of your personal information, delete, change or correct your personal information or access your personal information.

You can also change or withdraw your consent from the browsers. For further information to manage cookies on popular browsers please refer to: https://www.aboutcookies.org/how-to-delete-cookies/

If you block cookies on our website, you may be unable to access certain areas of our website and certain functions and pages will not work in the usual way.

Learn more about who we are, how you can contact us and how we process personal data in our Privacy Policy.

Changes to this Cookie Policy

We may update this Policy from time to time. Please regularly check this Policy to ensure you are aware of the most updated version.

This Cookie Policy was last updated on 30 September 2021.

BCEGI UK TAX STRATEGY

Chinese state owned Beijing Construction Engineering Group (BCEG) was founded in 1953 and began to expand internationally in 1990 with the establishment of Beijing Construction Engineering Group International (BCEGI). BCEGI is an international property developer and construction company specialising in bringing projects to fruition through strategic partnerships, investment and solid relationships. Today BCEGI is established in the UK (BCEGI Holdings (UK) Limited), along with America and Canada (BCEGI US).
This tax strategy sets out the approach to tax of all the UK entities of BCEGI Holdings (UK) Limited (collectively referred to hereafter as BCEGI UK) and to meet our requirements under Paragraph 19, Schedule 19 of the UK Finance Act 2016. This document has been approved by the board of directors for the period ended 31 December 2018 and will be reviewed and where necessary, updated, on a periodic basis.

Our Approach to Tax

As a Chinese state owned group, BCEGI UK’s overarching attitude to tax is to comply with all of our statutory reporting requirements in any territory we operate. We always act in accordance with all relevant tax laws and regulations and believe in paying the correct amount of tax when it is rightly due.
In pursuing our commercial objectives, we will consider, along with input from our professional advisors where required, the most appropriate way to conduct our affairs to comply with all applicable tax laws, rules, regulations and disclosure requirements, making use of any government offered reliefs and incentives. Effective tax rate is not a key performance indicator within BCEGI UK.
One of our key objectives is to ensure the reputation of BCEGI is not compromised. We will not enter into artificial transactions for the purpose of gaining a tax advantage.

Management of Tax

BCEGI UK take the management of our tax affairs very seriously, and tax is regularly discussed at board level (for example, when setting up new entities or dealing with significant transactions). As part of this approach, we entities seek advice from professional tax advisors and discuss the proposed transaction with our parent company in Hong Kong to ensure it is in line with the global BCEGI objectives.
Our experienced finance team is responsible for implementation and management of specific documented tax processes and policies to govern tax on a day to day basis, with support from professional advisors and the Group’s Corporate office where appropriate.
The UK Finance Director has overall responsibility for the oversight and management of the tax affairs of the UK entities, and is responsible for reporting to the Board regarding tax compliance and material tax uncertainties of the UK entities.

Working with HMRC

BCEGI UK seeks to have a collaborative and transparent working relation with HMRC based on honesty, openness and trust.
Where the interpretation or intent of legislation is unclear, we engage with our trusted professional advisors to clarify the correct treatment, and if appropriate, consider engagement with tax authorities in real time for clearance on position adopted.

Peter Chi
Finance Director
31 Jan 2021

DATA PROTECTION & CYBER SECURITY

STATEMENT OF INTENT

BCEGI is committed to the lawful and appropriate treatment of personal data and considers it critical to maintaining confidence between the business and all its stakeholders. The Company therefore fully endorses and adheres to the Principles of the General Data Protection Regulations in meeting both its statutory and contractual obligations in relation to information and cyber security (ICS). In doing so it will:

• Adopt a risk-based approach to ensure that ICS risks are treated in a consistent and effective manner.
• Protect and prevent information (e.g. confidential or sensitive) from unauthorised uses or disclosures.
• Ensure that ICS is integrated into essential business activities.
• Ensure that ICS delivers value and meets business requirements.
• Prioritise ICS resources to protect the business applications where an ICS incident would have the greatest impact.
• Comply with relevant legal and regulatory requirements to ensure that statutory obligations are met, stakeholder expectations are managed, and civil or criminal penalties are avoided.
• Provide timely and accurate reporting on ICS performance to support business requirements and manage ICS risks.
• Evaluate current and future ICS threats so that informed, timely action to mitigate risks can be taken.
• Promote continuous improvement in ICS to reduce costs, improve efficiency and effectiveness, and promote a culture of continuous improvement.
• Foster a security-positive culture that influences the behaviour of IT consumers to reduce the likelihood of ICS incidents occurring and limit their potential business impact.

RESPONSIBILITIES

Responsibility for this Policy ultimately lies with the BCEGI Lead Director.  Day to day responsibility lies with the IT Manager – supported by the Management Team – who is responsible for the implementation of the Policy Statement and associated arrangements.  This Policy Statement and associated arrangements are mandatory and apply to all employees, agency staff, temporary staff, professional bodies and supply chain partners who use any BCEGI IT services.   Workers are responsible themselves for not committing acts that are unlawful or leave the business open to Information & Cyber Security threats.

ARRANGEMENTS

This Policy Statement and associated arrangements are maintained in the BCEGI Integrated Management System (iMS).  They will be continually reviewed and improved in line with the needs of the business and to ensure ongoing compliance with legislation and best practice. It will be brought to the attention of all new workers during induction and will be available to all workers via the BCEGI iMS.

Compliance with this Policy Statement will be regularly monitored through the BCEGI internal audit programme, regular review of IT and business performance, monitoring of incidents and via the BCEGI Management Review process. Incidents of non-compliance may be treated as misconduct which may warrant dismissal from employment.

AUTHORISATION

Dongwen Yu
Lead Director
1^st Jan 2021

Management Standard – Coronavirus (COVID-19)

SCOPE

This Standard applies to all BCEGI employees and 3^rd parties across all BCEGI construction sites and offices.

PURPOSE

This Standard provides direction to BCEGI employees on the company’s requirements for Coronavirus (COVID-19).  It ensures that suitable and sufficient measures are established to protect the workforce and minimise the risk of spread of infection.

INTRODUCTION

Coronavirus (COVID-19) is an illness which infects the lungs. Coronavirus (COVID-19) spreads when an infected person coughs small droplets containing the virus into the air. These can cause an infection if breathed in, or if you touch a surface they have landed on and then touch your eyes, nose or mouth. Symptoms are a high temperature, a new continuous cough or a loss or change to your sense of smell or taste.

This Standard is intended to ensure consistent measures are in place across all BCEGI construction sites and offices
in line with the government guidance ‘Working safely during COVID-19 in construction and other outdoor work’
updated on 9^th  December 2021.

STANDARD

ATTENDING BCEGI CONSTRUCTION SITES AND OFFICES

Anyone (BCEGI and subcontractor staff included) with symptoms of COVID-19 (a high temperature, a new continuous cough or a loss or change to normal sense of taste or smell) must self-isolate immediately, even if their symptoms are mild. They should continue to self-isolate until they get a negative PCR test result or for the next 10 full days.

Anyone who has tested positive for COVID-19 must self-isolate immediately and continue for the next 10 full days, even if they’re fully vaccinated.

Anyone who has been told to self-isolate by NHS Test and Trace must do so as instructed.

Anyone who is a contact of an individual who test positive for COVID-19 must self-isolate for a period of 10 days, unless they’re fully vaccinated or under 18 years 6 months old. Contacts of individuals with a suspected or confirmed case of the Omicron variant, must self-isolate, regardless of their age or vaccination status.

Anyone that is higher risk as a result of physical health difficulties for example or has been advised to take specific health precautions by their GP, should inform their employer at the earliest opportunity to enable extra consideration to be given to their circumstances.

Any BCEGI staff that can reasonably work from home should work from home. Due to the continued need to manage our construction sites safely and effectively, staff members involved directly in site supervision/site management will not feasibly be able to work from home in most instances. All other staff members should work from home where they are reasonably able to do so.

There are no limits on contact between people from different households including in the workplace. There is no government requirement or recommendation for employers to limit capacity. BCEGI will apply the following general principles at company project and office locations to reduce contact for staff –

• Designated seating in offices so that staff work in consistent groups
• Staff to work / sit back-to-back or side-by-side in preference to face-to-face where space and capacity
  allow
• Screens / barriers to separate people who don’t normally mix and are required to work / sit face-to-face
• Skin to skin contact to be avoided
• Fixed teams / partnering to be implemented where possible

BCEGI site management will undertake a monthly COVID-19 ArrangementsInspection to monitor compliance with this management standard. Any instances of non-compliance will be reported to subcontractor site management where applicable and repeated non-compliance may result in site disciplinary action being taken.

PPE

Where workers are required to wear PPE for their specific task, to control the risk of spread of infection –

• Re-usable PPE is to be thorough cleaned after use
• Single use PPE is to be disposed of so that it cannot be reused

FACE COVERINGS

There is no government requirement for face coverings to be worn in construction and other outdoor working environments.

Face coverings will be made available at all BCEGI projects and offices. Staff (inc subcontractors) are encouraged to wear a face covering when walking around offices and welfare facilities and when in crowded and enclosed settings where they come into contact with people they do not normally meet.

If face coverings are worn it is recommended that staff –

• wash their hands thoroughly with soap and water for 20 seconds or use hand sanitiser before putting on face coverings. They should also do this before and after removing them
• avoid touching their faces or face coverings. Otherwise, they could contaminate them with germs from their hands
• change their face coverings if they become damp or they’ve touched them
• continue to wash their hands regularly
• change or wash their face coverings daily
• if the material is washable, to wash it in line with manufacturer’s instructions. If it’s not washable, to dispose of it carefully in their usual waste

TRAVEL TO AND FROM SITE/OFFICE

• If workers share a vehicle then they should –
  • Have fixed travel partners
  • Not sit face to face
  • Open windows
• Anyone who takes ill to be picked up by somebody from the same household if they are unable to get home safely on their own

ACCESS/EGRESS TO AND FROM SITE/OFFICE

• Staggered start and finish times for subcontractor staff on site to reduce contact between staff on access/egress routes and welfare facilities
• BCEGI and subcontractor staff to be signed in and out by security guard/gate attendant or card/facial scanners to be used – fingerprint scanners must not be used
• Signage to be displayed at access/egress points instructing BCEGI and subcontractor staff to wash/sanitise (60%+ alcohol based) hands upon arrival and departure
• Delivery drivers to be instructed by security guard/gate attendant to wash or clean hands before unloading goods/materials, hand sanitiser to be provided to security guard/gate attendant for this purpose

TOILET FACILITIES

• Signage to be displayed at entrance to facilities advising on need to wash hands before and after using the facilities
• Staggered break times for subcontractor staff on site to reduce contact between staff on access/egress routes and welfare facilities
• Enhanced cleaning regimes for toilet facilities to be established and scope of clean to be agreed. All door handles, locks, toilet flush, toilet roll holders, hand towel dispensers and taps must be cleaned during each clean
• Portable toilets to be avoided wherever possible, but where in use these are to be cleaned as part of the enhanced cleaning regime and emptied more frequently
• Suitable and sufficient rubbish bins to be provided for hand towels with regular removal and disposal
• Rooms should be well ventilated with windows open to allow fresh air circulation

CANTEENS AND EATING ARRANGEMENTS

• Signage to be displayed at entrance to facilities advising on need to wash hands before and after using the facilities
• Staggered break times for subcontractor staff on site to reduce contact between staff on access/egress routes and welfare facilities
• BCEGI and subcontractor staff are encouraged to bring pre-prepared meals and refillable drinking bottles from home to reduce the need for movement of people through access/egress points
• Hand sanitiser (60%+ alcohol based) to be available at the entrance of any room where people eat for use by staff before and after using the facilities
• Antibacterial wipes or antibacterial spray and paper towel to be available for staff to clean tables between each use
• All rubbish to be put straight in the bin and not left for someone else to clear up
• Enhanced cleaning regimes for canteen facilities to be established and scope of clean to be agreed. All tap mechanisms, chairs, tables, boiler taps and door handles must be cleaned at least at the end of each break and shift
• Rooms should be well ventilated with windows open to allow fresh air circulation

CHANGING FACILITIES, SHOWERS AND DRYING ROOMS

• Signage to be displayed at entrance to facilities advising on maximum users at any one time, 2m (or 1m with risk mitigation where 2m is not viable) distancing and need to wash hands before and after using the facilities
• Enhanced cleaning regimes for canteen facilities to be established and scope of clean to be agreed. All tap mechanisms, door handles, locks, seats and hand towel dispensers must be cleaned throughout the day and at the end of each day
• Suitable and sufficient rubbish bins to be provided for hand towels with regular removal and disposal
• Rooms should be well ventilated with windows open to allow fresh air circulation

SITE OFFICES

• Project Manager / Office Manager must ensure BCEGI and subcontractor office layouts are rearranged as necessary to allow staff to work / sit back-to-back or side-by-side in preference to face-to-face where space and capacity allow.
• Any BCEGI staff that can reasonably work from home should work from home, this will free up desk space in site offices for staff members involved directly in site supervision/site management.
• Rooms should be well ventilated with windows open to allow fresh air circulation.

ACCESS/EGRESS AROUND SITE/OFFICE

• Stairs to be used in preference to lifts or hoists
• Enhanced cleaning regimes for lifts/hoists and stairwells to be established and scope of clean to be agreed. Touchpoints, handrails, doors, buttons etc must be cleaned throughout the day and at the end of each day

SITE MEETINGS

• Online meetings to be undertaken where possible
• Rooms should be well ventilated with windows open to allow fresh air circulation
• Consider holding meetings in open areas where possible

CLEANING

Specific arrangements for cleaning are detailed in the sections above.  In general terms, enhanced cleaning procedures are to be put in place across all construction sites and offices, particularly in communal areas and at touch points including –

• Taps and washing facilities
• Toilet flush and seats
• Door handles and push plates
• Handrails on staircases and corridors
• Lift and hoist controls
• Machinery and equipment controls
• Food preparation and eating surfaces
• Telephone equipment
• Keyboards, photocopiers and other office equipment

Rubbish collection and storage points should be increased and emptied regularly throughout and at the end of each day.

SMOKING

• Staggered break times for subcontractor staff on site to reduce contact between staff on access/egress
  routes and welfare facilities

TEMPERATURE TESTING

• Anyone attending a BCEGI project or office for the first time should receive a temperature check prior to being inducted and having our COVID-19 arrangements explained to them. Also, we should communicate to BCEGI / subcontractor staff that anyone feeling unwell on arrival or during the
  workday should request a temperature check.
• Anybody with a temperature exceeding 37.8oC is not permitted access to company premises. Those who are not permitted to access company premises due to having a high temperature will be advised to use the NHS COVID-19 online assessment tool (https://111.nhs.uk/covid-19) in line with government
  advice at the time of writing. This measure applies to all persons entering company premises, including BCEGI staff.

SYMPTOMS OF CORONAVIRUS (COVID-19) IN THE WORKPLACE

• Where a member of BCEGI or subcontractor staff develops a high temperature, a persistent cough or a loss of or change in normal sense of taste or smell whilst at work, they should –
  • Return home immediately
  • Avoid touching anything
  • Cough or sneeze into a tissue and put it in a bin, or if they do not have tissues, cough or sneeze into the crook of their elbow
• The person experiencing symptoms should be picked up by somebody from the same household if they are unable to get home safely on their own
• The person experiencing symptoms should –
  • Self-isolate for at least 10 days from onset of symptoms
  • Arrange a test
  • Follow advice on text from test result
• Anyone who is a contact of an individual who test positive for COVID-19 must self-isolate for a period of 10 days, unless they’re fully vaccinated or under 18 years 6 months old. Contacts of individuals with a suspected or confirmed case of the Omicron variant, must self-isolate, regardless of their age or vaccination status.
• Project Manager must ensure a thorough clean of any identifiable affected areas/items is undertaken

SUBCONTRACTOR RISK ASSESSMENT

• Project Manager must ensure that every subcontractor on site has submitted a risk assessment specifically for Coronavirus (COVID-19). The risk assessment must be reviewed by the Project Manager using the RAMS Review form on the IMS prior to the subcontractor starting work on site.  Simply referencing BCEGI’s measures is not enough.  Subcontractors need to outline what they are doing to protect their employees, details of maintaining social distancing for work activities must be included and other things like cleaning vehicle cabs/equipment between use by different operatives.  

FIRST AID

• In the event of an accident occurring where the IP requires first aid –
  • Skin to skin contact is to be avoided
  • First aider and IP to wear eye protection, mask and gloves
  • Re-usable PPE is to be thorough cleaned after use
  • Single use PPE is to be disposed of so that it cannot be reused
• 999 to be called in the event of an emergency

In a non-emergency, anyone who takes ill to be picked up by somebody from the same household or by taxi if they are unable to get home/to hospital safely on their own.

MENTAL HEALTH AND WELLBEING

• BCEGI trained mental health first aiders available to support staff where needed
• Employee Assistance Programme. A confidential service designed to help employees deal with personal and professional issues that could be affecting their home or work life, their health or their general wellbeing.  Use the free 24-hour confidential helpline 0800 030 5182 for support such as –
  • Access to counselling services
  • Legal information
  • Medical information
• Wellbeing Portal which offers a range of support on a variety of health issues. Go to healthassuredap.com and use login details Username: BCEGI and Password: EAP
• TEAMS social area setup for staff to engage remotely with other staff on non-work-related topics
• Fortnightly welfare catch up call to BCEGI staff working from home

AFTERCARE WORK ACTIVITY

• Communicate with households before any visits, to discuss how the work will be carried out to reduce risk for all parties
• Do not carry out work in households that are isolating because one or more family members has symptoms
• When working in a household where somebody is clinically vulnerable, make prior arrangements to avoid any face-to-face contact. Be particularly strict about handwashing, coughing and sneezing hygiene, such as covering your nose and mouth and disposing of single-use tissues
• Ask households to leave all internal doors open, to minimise contact with door handles,
• Regular hand cleaning with soap and water or hand sanitiser
• Single use disposable gloves to be worn
• Face covering to be worn
• If operatives feel unwell, they are to go home and report this to supervisor
• Only essential staff to attend a household
• Work area must be thoroughly cleaned using regularly cleaning products before leaving

Operatives to carry anti-bacterial wipes to clean surfaces/handles before and after use.  Any shared tools or PPE to also be wiped down after use.

CORONAVIRUS (COVID-19) OUTBREAK

In the event of five or more cases of Coronavirus (COVID-19) occurring within 14 days at a company workplace, the SHEQ Director will advise the rest of the Senior Management Team and contact the local PHE health protection team.

If a construction site or office is not consistently implementing the measures set out in this management standard it may be required to close