ETI Corporate Transparency Framework

Base Code 1 | Employment is freely chosen

WGC have a standard recruitment process that meets all legal and ethical requirements. Each employee has the responsibility of completing their own starter pack information which includes submitting their own bank account details. This is uploaded to the I‑Trent payroll system, which would immediately identify if a bank account was being used by another employee and would be automatically rejected. The system would also reject a starter pack if a duplicate email was provided by more than one employee and this process would also identify and alert if there were multiple employee resident at the same home address. This would then lead to an investigation to determine the situation. During this onboarding process, all Right to Work documentation will be checked and verified prior to any employment commencement. Each location would have a poster regarding Modern Day Slavery and a confidential email address to be able to report any concerns.

Base Code 2 | Freedom of Association and the right to collective bargaining are respected

All employees have the right to join or form Trade Unions of their own choosing. WGC Limited has a very close relationship with Unite the Union as evidenced by supporting our new Ukrainian staff with ESOL classes, free of charge. This has also been extended to all employees who have English as a second language. WGC also welcomes Trade Union representation at disciplinary and grievance meetings. WGC work closely with Unite the Union on Health and Safety initiatives in the housekeeping sector.

Base Code 3 | Working conditions are safe and hygienic

All WGC staff work on client’s premises, and we ensure that the conditions on these sites provide a safe and hygienic working environment for
our team members. All employee’s complete induction training prior to commencing work which is then reviewed with mandatory refresher training supplied on an annual basis. Risk Assessments are completed as part of our return-to-work process, following periods of sickness if applicable. They are also conducted for all pregnant employees at various stages of their pregnancy. If a team member discloses a disability, a risk assessment would be carried out and reasonable adjustments made. WGC has a Health and Safety Committee that monitors and reviews all Health and Safety standards and procedures. This committee is led by a Health and Safety Representative.

Base Code 4 | Child labour shall not be used

WGC adhere strictly to all regulations regarding the employment of any team member or any employee under the age of 18. Additional supervision and longer breaks as per the regulations are implemented at each location. Young people’s Risk Assessments are carried out prior to any employment. All young people are paid the same rate of pay as all other team members and not at a reduced rate due to age.

Base Code 5 | Living wages are paid

All rates of pay have been increased to that higher than the National Living Wage across WGC. All employees automatically receive their contract of employment on day one, when their new starter pack is completed. Any deduction from wages is included in the contract of employment.

Base Code 6 | Working hours are not excessive

All employees have the opportunity to agree to the Working Time Directive. If they wish to work above 48 hours per week, they have to request to opt out of the agreement. An excessive hour’s report is sent to all senior management team on a monthly basis, any concerns would be
raised and investigated immediately. Employees have to sign in and out themselves to ensure that they are paid for every hour they have worked. Payroll audits are carried out on a monthly basis at every location by a senior member of staff to verify compliance.

Base Code 7 | No discrimination is practiced

Equality, Diversity and Inclusion is a priority for WGC. It is an essential part of the onboarding process for all employees. Training takes place on a regular basis to reinforce our policy and procedures. The HR contact details are visible at each WGC location and employees are
encouraged to raise any concerns. Any concerns raised would be investigated immediately and appropriate action taken. As part of the management development program, all managers have attended Equality, Diversity and Inclusion training in the past year. Equality, Diversity and Inclusion is embedded in the WGC mandatory Behaviours which are applicable to all staff.

Base Code 8 | Regular employment is provided

All new employees have the opportunity to choose the number of contracted hours they wish to work to fit their personal circumstances. A report is produced every month from the payroll department to the senior management team for any employees that have not had hours
worked during that period. All employees are employed on a permanent contract to ensure regular employment is provided. WGC also promote Flexible Working as and when possible.

Base Code 9 | No harsh or inhumane treatment is allowed

If any concerns were raised by employees regarding physical, sexual, harassment or bullying, these would be dealt with as a priority and
investigated thoroughly. This is also monitored though analysis of all leaver comments. WGC has zero tolerance for any physical, sexual, harassment or bullying or any other form of intimidation.

A new WGC Board member has been appointed to oversee governance of all areas of the business. They will take responsibility for ensuring compliance with governance and accountability regarding all our ethical trade standards. There is a monthly senior team meeting attended by the CEO where any issues or concerns would be raised. The Board of Directors hold 3‑monthly meetings and our ETI commitments are discussed and approved.

WGC’s supply chain is now growing, and a great deal of work is being undertaken by the senior management team. We are also partnering with Ecovadis to collaborate on sustainability with a common platform, universal scorecard, benchmarking and performance improvement tools, all processes and documentation are currently being updated and will be available post March 2024. WGC have a variety of clients that are increasingly looking to work with ethical suppliers. When we bid for a new contact or an expiring contract that is going out to tender, WGC must be able to demonstrate their ethical processes and practices. WGC have regular audits by our clients where we are able to evidence that we meet all the above base code requirements. WGC have to provide Right to Work documentation, payslips evidencing paying at or above the National Minimum Wage and individuals contracts of employment.

All employees have the right to join or form Trade Unions of their own choosing. WGC Limited has a very close relationship with Unite the Union as evidenced by supporting our new Ukrainian staff with ESOL classes free of charge which has now been extended to all staff with English as a second language. WGC welcome Trade Union representation at disciplinary and grievance meetings. WGC work closely with Unite the Union on Health and Safety initiatives in the housekeeping sector.

The majority of WGC clients are within the hospitality sector where there is a high risk of exploitation. Therefore, WGC ensure we implement due diligence with a focus on sector specific risks. We are audited by our clients on an ongoing basis and have never had any concerns raised to date, in fact, we have been deemed to have a very robust approach. WGC has a specific training video regarding Modern Day Slavery, and this is accompanied by a poster in each location. WGC work with different cultural behaviours which could lead to discrimination between colleagues. WGC conduct robust Equality and Diversity training and support. Making sure all staff have Equality and Diversity training for all staff and detailed training for management. WGC identify the risks of sexual harassment and verbal abuse by its clients’ guests. WGC work
closely with their clients to ensure that guests are asked to leave and do not return.

A detailed document is being produced regarding our First Tier Suppliers who are all UK based. We are working closely with our First Tier Suppliers to ensure that they are fully compliant and ethical in terms of trading standards and initiatives. The comprehensive details will be available by March 2024.