The Company is responsible for the care and safeguarding of some of the most vulnerable people in society.

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1 Page 1 of 6 Title of Policy: Disclosure and Barring Section: Human Resources Statement The Company is responsible for the care and safeguarding of some of the most vulnerable people in society. This responsibility is undertaken through its workforce of devoted and dedicated individuals who show exemplary qualities of care and compassion. Our ability to feel confident that our employees possess these, and other important qualities, is because we take our recruitment seriously. This includes exercising sound judgement, and undertaking checking procedures available to and required of us, such as taking up references, confirming qualifications and experience, and ensuring that no individual offered employment with us has either a criminal record which is serious enough for us to withdraw or is someone who is on a list of individuals who are barred from working with vulnerable adults or children, and whose employment would be illegal. Criminal record checks, together with checks on barred lists, are made through Disclosure Scotland. The Company will make relevant checks on all prospective employees occupying qualifying positions. Procedure and Guidance Disclosure Scotland Summary Disclosure Scotland helps employers make safer decisions when they're recruiting people. It also makes sure unsuitable people don't work with vulnerable groups, including children and protected adults. What it does If an employer wants to hire someone, they can ask Disclosure Scotland for a certificate which gives details of the person's criminal convictions. If the person doesn't have a criminal record, the certificate will make it clear to the employer that they have no convictions. Disclosure Scotland also manages the Protecting Vulnerable Groups Scheme. This is a membership scheme for people who work with children or vulnerable adults. Employers can check a member's record at any time to make sure they're still safe to work with these groups. To keep these records accurate, Disclosure Scotland can access a range of police data, as well as data from other sources. Its responsibilities include: issuing certificates for criminal records checks for basic, standard or enhanced disclosures; adding people doing work with vulnerable groups to the PVG Scheme; deciding whether a person should be added to or removed from a barred list; maintaining the barred lists for regulated work with children or protected adults.

2 Page 2 of 6 Disclosures Basic Disclosure Certificate Anyone can apply for a Basic Disclosure Certificate, for any reason, for example: a job application; voluntary work; an airport security pass. A basic disclosure certificate shows any 'unspent' criminal convictions an individual may have in the UK. Under the Rehabilitation of Offenders Act 1974, some criminal convictions can be treated as 'spent' meaning they're not relevant to basic disclosure after a certain length of time. Standard and enhanced disclosures Standard and enhanced disclosures involve higher level checks. They are for people doing certain types of work or looking to adopt and are applied for by your employer or a registered body representing you. standard disclosure is for specific roles such as solicitors, accountants or providing a care service; enhanced disclosure applies to specific roles such as checking people are suitable for adoption, or applying for certain gaming or lottery licences. Protecting Vulnerable Groups The Protecting Vulnerable Groups (PVG) membership scheme is managed and delivered by Disclosure Scotland. It helps makes sure people whose behaviour makes them unsuitable to work with children and/or protected adults, can't do regulated work with these vulnerable groups. There are 2 types of regulated work work with children and work with protected adults. Regulated work is usually jobs including: caring responsibilities; teaching or supervising children and/or protected adults; providing personal services to children and/or protected adults; having unsupervised contact with children and/or protected adults. All employees of the Company who undertake regulated work will be required to be members of the PVG Scheme. How the scheme works When someone applies to join the PVG Scheme Disclosure Scotland carries out criminal record checks and shares the results with individuals and organisations. The application process involves gathering criminal record and other relevant information. This can be shared with the employer who is providing regulated work, unless the person applies to have a conviction removed from their PVG Scheme record. If the information shows the applicant might be unsuitable for regulated work, they'll be referred for further investigation as part of the 'consideration process'. Once someone is a PVG scheme member Disclosure Scotland keeps checking their suitability to continue working with children or protected adults. If they find new information which means someone might have become unsuitable to work with children or protected adults, they'll tell their employer.

3 Page 3 of 6 'Harmful behaviour' by PVG scheme members If the courts, police, regulatory bodies or previous employers provide information to Disclosure Scotland which suggests someone may be unsuitable for regulated work, this will trigger a consideration for listing. If Disclosure Scotland decides that someone's unsuitable to do regulated work with vulnerable groups, they'll bar them from working with children and/or protected adults, and inform their current employers. They'll also remove them from the PVG Scheme and tell any other employers listed on their record that they have been barred. How long does it last? A PVG Scheme member's paper certificate shows the information available on the day it was created. Membership of the scheme lasts forever though, and scheme members are continuously checked, unless they decide to leave the scheme. Types of PVG disclosure record If you join the PVG Scheme, you will get a PVG disclosure record. There are 3 different types of PVG disclosure record: Scheme Record; Short Scheme Record; Scheme Membership Statement; Which type of PVG disclosure record you need depends on what you need it for and whether you are already a member of the PVG Scheme. Types and uses of PVG disclosure record Type Who is it for? Cost Includes vetting information? Scheme Record Short Scheme Record People who want to join the PVG Scheme to do regulated work for an organisation PVG Scheme members joining a new organisation for the same type of regulated work, and have had a scheme record issued for that type of work before 59 Yes 18 No Scheme Membership Statement People who want to do regulated work in the future, people who are self-employed and doing regular work, or private individuals (personal employers) employing someone to do regulated work for them 18 (existing PVG Scheme members) 59 (new applicants to the PVG Scheme) No What your PVG disclosure record shows All PVG Scheme records show the following information: Name; Address; date of birth;

4 Page 4 of 6 PVG Scheme membership number; disclosure number of the Scheme Record; the type of regulated work the person is a PVG Scheme member for confirmation that the person isn't barred from doing that work if the person is under consideration for listing for that type of regulated work This information is the scheme member's statement of scheme membership. Each PVG disclosure record will also have a disclosure number. What other information is shown depends on the type of PVG disclosure record: Scheme Record A Scheme record provides the following information: Membership information the scheme member's statement of scheme membership name and address of the registered body and countersignatory details (on the registered body's copy only) name and address of the regulatory body and registration number (on the regulatory body's copy only, if necessary) Vetting information unspent convictions spent convictions for certain offences unspent cautions if the person is on the sex offenders register relevant information from the police force prescribed civil orders Short Scheme Record Membership information the scheme member's statement of scheme membership name and address of the registered body and countersignatory details Vetting information no vetting information is included Scheme Membership Statement Membership information the scheme member's statement of scheme membership name and address of the personal employer (on the personal employer's copy only) Vetting information no vetting information is included

5 Page 5 of 6 Applications to Disclosure Scotland to join the PVG Scheme All employees of the Company with caring responsibilities (including direct contact with Clients) will be subject to the PVG Scheme and appropriately vetted before commencement of duties. Either: This process is undertaken directly by the Company with Disclosure Scotland Or: The Company has identified an Umbrella Body to handle all applications for membership of the PVG Scheme, and has satisfied itself that this organisation is aware of, and complied with, the Code of Practice in connection with the use of disclosure information. Either: The costs incurred in respect of membership of the Scheme will be borne by the Company. Or: The costs incurred in respect of membership of the Scheme will be borne by the employee. EU Nationals applying for roles with children Disclosure Scotland checks your criminal history information held in the UK, as well as from your country of nationality, if your nationality is one of the following: Germany, Lithuania, Netherlands, Portugal, Romania, Hungary, Greece, France, Ireland, Italy, Spain, Poland. Make a referral to Disclosure Scotland If an organisation or employer has employees or volunteers doing 'regulated work', they have a duty to report any harmful behaviour that might affect whether the person is allowed to work with children or protected adults. This applies whether the person is a member of the PVG Scheme or not. This is called making a referral. By law, employers must report harmful behaviour even if it takes place outside of work, or the employer only finds out about it after the employee or volunteer has left. When to make a referral to Disclosure Scotland The employer must make a referral to Disclosure Scotland explaining what's happened. This only has to be done if the harmful behaviour meant that the person involved: was dismissed as a result would have been dismissed but left before they could be was transferred permanently away from work with children or protected adults If any of these disciplinary actions were taken, the company or employer must make a referral to Disclosure Scotland within 3 months of the decision being made. Harmful behaviour that should be referred The following are examples of harmful behaviour which should be referred: harming a child or protected adult placing a child or protected adult at risk of harm

6 Page 6 of 6 inappropriate behaviour involving pornography inappropriate behaviour of a sexual nature involving a child or protected adult giving inappropriate medical treatment to a child or protected adult Types of harm There are a number of different ways 'harm' can be defined. It's also important to bear in mind that people can cause a risk of harm without actually doing anything directly. Examples of harm include: physical harm (like inappropriate physical restraint or assault); psychological harm (like emotional abuse); theft (like embezzlement); Examples of behaviour which lead to a risk of harm include: attempting to harm (even if they don't succeed) trying to make someone else cause harm encouraging someone to self-harm reckless behaviour or incompetence that may cause someone to be harmed as a result, even if they didn't mean it to How to send a referral If an employee or volunteer has been permanently removed from work for harmful behaviour towards a child or protected adult, the employer or organisation has to send an employer referral form to Disclosure Scotland. The form asks for: proof of the person's identity (name, address, date of birth, national insurance number); details of the type of regulated work they're employed to do; the person's PVG scheme number; information on the harmful behaviour; details and documentation relevant to the employer's investigation and outcome. The referral shouldn't identify any children or protected adults by name..