• Policy Statement- Code of Ethics

UXO Groundworks Ltd seeks to be a good corporate citizen in everything that it does.

We have therefore determined to bring together our existing operating principles into one framework policy under the heading of Corporate Social Responsibility (CSR). The principles encompassed in this policy cover all areas of the company’s operations and have been developed and continue to be reviewed against and updated by reference to relevant codes of corporate governance and international standards. 


This code applies to all of the operations of the organisation and sets out the minimum standards which the management expects from all personnel in their internal and external dealings with colleagues, customers, and third parties.


1.1 Basic Standards of Conduct

  • We will conduct every aspect of our business with honesty, integrity and openness, respecting human rights and the interests of our employees, customers and third parties.
  • We will respect the legitimate interests of third parties with whom we have dealings in the course of our business.
  • We will maintain the highest standards of integrity – for example, we will not promise more than we can reasonably deliver or make commitments we cannot or do not intend to keep.


1.2 Personnel

UXO Groundworks Ltd:

  • Will strive to create a workplace in which there is mutual trust and respect and where every person feels responsible for the performance and reputation of our company.
  • Will respect the individual and each other’s rights, customs and traditions including the right to freedom of association and the right to decide whether or not to join a trade union and will negotiate in good faith with the properly elected representatives of its employees.
  • Will work towards achieving a diverse workforce, recruiting, employing and promoting employees only on the basis of objective criteria and the qualifications and abilities needed for the job to be performed.
  • Will maintain good communications with employees through our information and consultation procedures.
  • Will assist personnel in realising their potential.


1.3 Customers

UXO Groundworks Ltd is committed to providing safe, value for money, high quality, consistent, accessible and reliable products and services to its customers. Our aim is to provide all of our products and services, in a safe, responsible, professional and timely manner. When a customer does business with us, the customer can be sure we will do everything possible to provide the best quality of service and value for money.

We will

  • Act in accordance with fair business, marketing and advertising practices and take all reasonable steps to ensure the safety of our services
  • Not make representations or omissions nor engage in any other practices that are deceptive, misleading, counterfeit, fraudulent or unfair
  • Respect customer privacy and provide protection for personal data 


1.4 Suppliers

Ethical Purchasing Policy

  • We purchase a wide range of goods and services required in the operation of our business and we also rely heavily on a number of key suppliers for the delivery of our core services. Good working relationships with our suppliers are therefore central to the success of our business
  • We are committed to obtaining and retaining competitive goods and services while at the same time ensuring they are from sources which have not jeopardised human rights, safety or the environment.
  • We aim to develop strong relationships with our suppliers, based on mutual trust, understanding and respect.
  • We will report any suspected supplies of good or services that we believe to be counterfeit or fraudulent.  


  • More specifically we expect our suppliers to: 
    • Adhere to business principles consistent with our own.
    • Seek to maintain continuous improvement in their supply chain relationship with us.


1.5 Business Partners 

  • We aim to develop strong relationships with our suppliers and others with whom we have dealings, based on mutual trust, understanding and respect.
  • In those dealings, we expect our partners to adhere to business principles consistent with our own.


1.6 Community

UXO Groundworks Ltd are a company that supports small local companies, products and services and the relationships with our community. And where possible will provide employment opportunities in the local area.


1.7 Compliance with Law

  • All members of the company will comply with the laws and regulations applicable wherever they do business. Appropriate training will be provided for personnel as necessary.


1.8 Business Integrity

    • UXO Groundworks Ltd will not offer, give, seek or receive, either directly or indirectly, inducements or other improper advantages for business or financial gain and no member of personnel may offer, give, seek or receive any gift or payment which is, or could be construed as, such. 
    • UXO Groundworks Ltd accounting and other records and supporting documents will accurately describe and reflect the nature of the underlying transactions.
  • No undisclosed or unrecorded account, fund or asset will be established or maintained.
  • UXO Groundworks Ltd will not facilitate, support, tolerate or condone any form of money laundering.


1.9 Conflicts of interest and confidentiality

  • Whilst UXO Groundworks Ltd respects the privacy of its personnel, all personnel are expected to avoid personal activities and financial interests, which could conflict with their responsibilities to the company.
  • UXO Groundworks Ltd personnel must not seek gain for themselves or others through misuse of their positions or company property.
  • All actual and potential conflicts (including those arising from the activities or interests of close relatives or partners) should be disclosed to and discussed with the appropriate line manager.
  • Information received by anyone in the course of his or her employment must not be used for personal gain or for any purpose other than that for which it was given.
  • Where information is confidential, that confidentiality must be respected.
  • UXO Groundworks Ltd maintains a corporate whistle blowing policy.


  • Security

2.1 Security

Security is key for our personnel and our business. We recognise the range of security issues which can arise and are astringent on ensuring safety and security for our business practices.


  • UXO Groundworks Ltd is committed to ensuring, so far as is reasonably practicable, the security of our sites, customers, personnel and our property.
  • Security is an area in which we seek continuous development and improvement. We will heighten the profile of security to ensure all personnel understand why they should and how they can play their part. 


This statement provides guidance and direction to all personnel on what is both required and expected of them. We are confident our personnel will appreciate the reasons for this and the benefits to them, their colleagues, our customers and our property.


We aim to achieve, so far as is reasonably practicable: –

  • A secure environment for customers and visitors 
  • A secure environment for personnel, contractors and subcontractors in their workplace
  • Security of our property
  • Security of our systems and processes


 2.2 Actions

To maintain security all personnel, play a role to support the system

    • Personnel are actively encouraged to report security concerns. 
    • Risk analysis is undertaken regularly.
    • Property is secured in responsible and safe manners.
    • Unauthorised persons are not permitted on UXO Groundworks Ltd property.
  • Entry and departure to the site is logged by a system of reporting to the reception area.

  • Employment

UXO Groundworks Ltd encourages and has adopted a policy of openness, sustainability and respect for personnel rights. 


3.1 Equal Opportunities and Diversity Policy

UXO Groundworks Ltd is committed to equality of opportunity, in the provision of its services, as an employer, and as a receiver of supplied goods, services and equipment. This policy sets out UXO Groundworks Ltd.’s commitment to treat equally and with fairness at all times its personnel, customers, contractors, suppliers and those who come into contact with the company.

We are committed to compliance with legislation based on the following principles.

  • Everyone has the right to be treated with dignity and respect.
  • We will not discriminate on the grounds of race, gender, disability, nationality, religion, philosophical belief, political belief, age, sexual orientation, family status, trade union activity or any other factor.
  • We will adopt fair and inclusive practices throughout our operations and will seek to eliminate all prejudice, discrimination, bullying and harassment.
  • All personnel have a personal responsibility for the practical application of this policy in their day-to-day activities and must support the policy at all times.
  • Non-compliance with this policy will be treated seriously and will not be tolerated.


The Company Management and Directors of UXO Groundworks Ltd are required to ensure:

  • They create a productive and safe working environment, promoting diversity and inclusion in their workforce.
  • They develop new practices, as appropriate, to ensure all employees, contractors and customers are treated fairly; and they can demonstrate continuous improvement in practices to promote diversity and equal opportunities for all.


Access to Company Premises

  • We will take all reasonable steps to ensure that our premises are accessible to disabled personnel, customers and visitors as required by the Disability Discrimination Act (DDA) 
  • We will also take reasonable steps to ensure that our vehicles are accessible to customers and staff and comply with the relevant legislation for the country in which they operate.


Access to Information

  • We will seek to ensure that information is made available to our customers and employees in alternative formats as required.



  • All recruitment will be carried out with regard to fairness, equality and consistency for all candidates at all times. Recruitment practices will be inclusive, and we will endeavour to ensure there are no barriers to employment of suitable candidates.



  • Any employee who feels that he or she has grounds for complaint in relation to bullying, discrimination, harassment or victimisation has the right to pursue the complaint through our grievance procedures.
  • Any person who feels or suspects misconduct, illegal acts or failure to act within the company can report this using the company Whistleblowing policy to alleviate fear of victimisation, subsequent discrimination, disadvantage or dismissal
  • Customers who feel they have grounds for complaint may pursue these by directly contacting the company Directors.


3.2 Human Rights

UXO Groundworks Ltd will adhere to the following principles in respect of our personnel.

  • We will treat all personnel fairly and honestly, regardless of where they work. All personnel will have agreed terms and conditions in accordance with local law or practice and will be given appropriate job skills training.
  • We will pay a fair wage reflecting local markets and conditions. We will always meet any national minimum wage.
  • Working hours shall not be excessive. They shall comply with industry guidelines and working time regulations 
  • We will not employ illegal child labour, forced or bonded labour, forced overtime or condone illegal child labour.
  • We will not contribute to human trafficking, or employ labour associated. We will report to authorities any suspected cases of human trafficking or offers thereof, in compliance with disclosure obligations under the Modern Slavery Act 2015.
  • We will not aid or abet slavery, servitude or forced compulsory labour, or tolerate the counselling or procuring of this, any suspected cases will be reported to authorities in compliance with disclosure obligations under the Modern Slavery Act 2015.
  • Personnel have the rights of freedom of association and collective bargaining. We respect the right of our personnel to choose whether or not to join a trade union without influence or interference from Management 
  • We will abide by the non-discrimination laws in every country where we operate.
  • We will not use or condone the use of corporal punishment, mental or physical coercion or verbal abuse. We have disciplinary procedures for any member of personnel whose conduct falls below the required standard.
  • We have formal grievance procedures through which staff can raise personal and work-related issues.
  • Personnel welfare will always be of the utmost importance


3.3 EU General Data Protection Regulation (GDPR) & Data Protection


Company- Means UXO Groundworks Ltd a registered company.

GDPR- Means the General Data Protection Regulation.

Responsible Person- Means the person responsible for data protection within the company

Register of Systems- Means a register of all systems or contexts in which personal data is processed by the company.


  1. Data protection principles

The Company is committed to processing data in accordance with its responsibilities under the GDPR. 

Article 5 of the GDPR requires that personal data shall be:

  1. processed lawfully, fairly and in a transparent manner in relation to individuals.
  2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
  4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
  5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
  6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
  1. General provisions
  1. This policy applies to all personal data processed by the Company. 
  2. The Responsible Person shall take responsibility for the Company’s ongoing compliance with this policy. 
  3. This policy shall be reviewed at least annually. 


  1. Lawful, fair and transparent processing 
  1. To ensure its processing of data is lawful, fair and transparent, the Company shall maintain a Register of Systems. 
  2. The Register of Systems shall be reviewed at least annually. 
  3. Individuals have the right to access their personal data and any such requests made to the company shall be dealt with in a timely manner. 
  1. Lawful purposes
  1. All data processed by the company must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information). 
  2. The Company shall note the appropriate lawful basis in the Register of Systems.
  3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data. 
  4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Company’s systems.  
  1. Data minimisation
  1. The Company shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. 
  2. The company will annually review personal data held, and responsibly dispose of any data that is no longer required. 
  1. Accuracy
  1. The Company shall take reasonable steps to ensure personal data is accurate. 
  2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date. 
  1. Archiving / removal
  1. To ensure that personal data is kept for no longer than necessary, the Company shall document its retention periods for each area in which personal data is processed and review this against stored files annually. 
  2. Retention periods for personal data are based on statutory and professionally recommended requirements. 
  1. Security
  1. The Company shall ensure that personal data is stored securely using modern software that is kept-up to date.  
  2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information. 
  3. When personal data is deleted this should be done safely such that the data is irrecoverable. 
  4. Appropriate back-up and disaster recovery solutions shall be in place. 
  1. Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Company shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).