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COMMUNITY WORK PLACEMENTS G4S Legal/VP/April 2014 1 APPENDIX 1 INFORMATION MANAGEMENT AND DATA SECURITY 1. General There is no relief from Contract Performance obligations because of unavailability of the G4S Case Management System, iSET (“G4S IT System”) The G4S IT System is provided solely for use in the context of delivering the contracted Services. Any information relating to the G4S IT System is not to be copied or allowed to fall into third-party hands without G4S approval. Obligations in this Appendix are to be propagated to all the G4S Sub-Contractor’s. Training material provided to the G4S Sub-Contractor’s is provided only for the purposes of training G4S Sub-Contractor staff delivering the Services and is not to be copied or provided to any third parties without the Approval of G4S. G4S will review the G4S Sub-Contractor’s Security Plan when submitted by the G4S Sub-Contractor in accordance with this Appendix, and at least annually thereafter. 2. Storage of Information The G4S Sub-Contractor shall retain all documentation relating to the provision of the Services and the CWP programme delivery, and will be required to retain this documentation until at least 31 st December 2030. This will include: a. a complete audit trail of all relevant documents as outlines in the Contractor Guidance and G4S Compliance Guidance at all stages of the process; b. individual Participant documentation that provides evidence for payment claims; c. evidence to show compliance with DWP publicity requirements, sustainable development, equality and diversity, and equal opportunities; d. a document retention policy. This should comply with the DPA and needs to be submitted to G4S within four (4) weeks of Contract Commencement. The G4S Sub-Contractor shall provide to G4S access to all programme material, which can be published to promote the CWP programme in accordance with the Contractor Guidance. 3. G4S IT System All G4S Sub-Contractors shall use the G4S IT System to record the activity of the CWP Programme. The G4S Sub-Contractor shall ensure that all activity is inputted on the G4S system, and only, by staff trained on the G4S IT System and who have obtained the necessary security clearance, BPSS. In the event that the G4S IT System is not available, the G4S Sub-Contractor must securely keep manual records of all activities relating to the CWP Programme. These records must be inputted into the G4S IT System within five (5) working days once

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APPENDIX 1

INFORMATION MANAGEMENT AND DATA SECURITY

1. General

There is no relief from Contract Performance obligations because of unavailability of the G4S Case Management System, iSET (“G4S IT System”) The G4S IT System is provided solely for use in the context of delivering the contracted Services. Any information relating to the G4S IT System is not to be copied or allowed to fall into third-party hands without G4S approval. Obligations in this Appendix are to be propagated to all the G4S Sub-Contractor’s. Training material provided to the G4S Sub-Contractor’s is provided only for the purposes of training G4S Sub-Contractor staff delivering the Services and is not to be copied or provided to any third parties without the Approval of G4S. G4S will review the G4S Sub-Contractor’s Security Plan when submitted by the G4S Sub-Contractor in accordance with this Appendix, and at least annually thereafter. 2. Storage of Information

The G4S Sub-Contractor shall retain all documentation relating to the provision of the Services and the CWP programme delivery, and will be required to retain this documentation until at least 31st December 2030. This will include:

a. a complete audit trail of all relevant documents as outlines in the Contractor

Guidance and G4S Compliance Guidance at all stages of the process;

b. individual Participant documentation that provides evidence for payment

claims;

c. evidence to show compliance with DWP publicity requirements, sustainable

development, equality and diversity, and equal opportunities;

d. a document retention policy. This should comply with the DPA and needs to

be submitted to G4S within four (4) weeks of Contract Commencement.

The G4S Sub-Contractor shall provide to G4S access to all programme material, which can be published to promote the CWP programme in accordance with the Contractor Guidance. 3. G4S IT System

All G4S Sub-Contractors shall use the G4S IT System to record the activity of the CWP Programme. The G4S Sub-Contractor shall ensure that all activity is inputted on the G4S system, and only, by staff trained on the G4S IT System and who have obtained the necessary security clearance, BPSS. In the event that the G4S IT System is not available, the G4S Sub-Contractor must securely keep manual records of all activities relating to the CWP Programme. These records must be inputted into the G4S IT System within five (5) working days once

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the system is available again. Once manual records have been loaded into G4S IT System, the manually created records must be destroyed immediately. Information from any other source shall not be used to evidence that Contract Performance is being achieved. Using G4S IT System:

a. any G4S Sub-Contractor staff, advisor, administrator or operations manager

accessing the G4S system through Role Based Access Controls (RBACS)

will, in accordance with Government requirements, be vetted to BPSS

standards or equivalent;

b. all Staff must provide evidence that BPSS clearance has been obtained to

request an G4S IT System account;

c. prior to requesting an G4S IT System login all staff must be trained in the use

of the G4S IT System. This training will cover system security, data

transferring and handling to ensure compliance with DWP and CWP

Programme contract requirements;

d. the G4S Sub-Contractor shall be responsible for providing G4S IT System

training for all staff with access to the G4S IT System;

e. DWP information must not be shared from the G4S IT System to other

systems or storage media and must not be transcribed onto paper except to

enable continuity of business in the event that the G4S IT system becomes

unavailable.

To use the G4S IT System the G4S Sub-Contractor shall use equipment and software conforming to the following:

Minimum specification

a. A personal computer or laptop running Microsoft Windows version 7; b. Internet Explorer Version 11; c. Microsoft office 2010 or higher; d. Adobe acrobat reader; e. Critical Windows service packs, security and office updates applied; f. Anti-Virus (updated daily); g. Hard drive encryption.

Internet Browser settings

a. password saving disabled.

b. browsing history, cache and temporary files set to delete on exit

c. pop-up blocker disabled (G4S named website)

d. G4S named website added to the trusted sites list

4. IT Contact.

G4S require a named IT contact prior to contract start. Contact details (Full Name, Telephone Number & Email Address) to be registered with G4S via email [email protected]. G4S must be informed if there is a change to the named IT contact within five (5) working days of such change.

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5. Offshoring

DWP Programme data and G4S Data shall not be processed outside the European Economic Area without the prior written consent of DWP/G4S and shall comply at all times with the Data Protection act 1998 (“DPA”)

6. Premises Security

Premises where DWP Programme data will be processed shall have secure access controls and buildings which are compliant with DWP Security Standards.

7. Security Incidents

Processes for identifying, managing and reporting actual or suspected security breaches shall be in place and will be auditable by G4S. The G4S Sub-Contractor shall implement appropriate arrangements to ensure that all information relating to the CWP Programme, the Services and any other programme assets are protected in accordance with prevailing statutory and central government requirements. The G4S Sub-Contractor shall comply with the relevant standards from the DWP Information Systems Security Standards, which are based on ISO 27001. The G4S Sub-Contractor agrees to comply with these policies and standards and appoint a named officer who will act as first point of contact for security issues. Within ten (10) working days of commencement of this Contract, the G4S Sub-Contractor shall submit a Security Plan detailing all physical, technical, procedural and organisational measures taken by the G4S Sub-Contractor to ensure the security of personal information handled in relation to the Services. G4S will review the G4S Sub-Contractor’s Security Plan within 10 Working Days and will provide observations where improvements are required to the G4S Sub-Contractor’s Security Plan. The G4S Sub-Contractor shall revise their Security Plan to take account of G4S observations within ten (10) working days of receipt of G4S’ observations and will resubmit the Security Plan to G4S. The G4S Sub-Contractor’s Security Plan shall be reviewed at least annually thereafter by G4S and the G4S Sub-Contractor. If at any time G4S requires changes to the G4S Sub-Contractor’s Security Plan, the G4S Sub-Contractor will make such changes within ten (10) working days of notification by G4S. The G4S Sub-Contractor will ensure that its operations are consistent with its Security Plan at all times. Attached to this Appendix:

Annex 1 – G4S IT SYSTEM Acceptable Use Policy

Annex 2 – G4S IT SYSTEM Information Security Policy

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APPENDIX 2

DIVERSITY AND EQUALITY REQUIREMENTS

1. General

1.1 The G4S Sub-Contractor acknowledges that G4S has a ‘duty to promote’ equality and must at all times be seen to be actively promoting equality of opportunity for, and good relations between, all persons, irrespective of their race, gender, gender reassignment, disability, age, sexual orientation or religion/belief or in terms of pregnancy and maternity or marriage and civil partnership. The G4S Sub-Contractor must ensure that each Sub-Contractor involved in delivery of the Contract is aware of, and acknowledges, that G4S has a ‘duty to promote’ equality.

1.2 In delivering the Services, the G4S Sub-Contractor shall, and shall procure that each Sub-Contractor shall, assist and cooperate with G4S in satisfying equality duties by fully complying with the requirements of this Appendix and the Equalities Act.

2. Compliance

2.1 The G4S Sub-Contractor acknowledges the provisions of the equality legislation set out in Clause 4.2 (Non-Discrimination).

2.2 The G4S Sub-Contractor shall produce a Diversity and Equality Delivery Plan in accordance with paragraph 2.5 (and sub paragraphs) and paragraph 2.6 (and sub paragraphs) of this Appendix, within six (6) Months of the Commencement Date, and annually thereafter. The Diversity and Equality Delivery Plan must be specific to the Contract and include details for all Sub-contractors involved in delivery of the Contract.

2.3 The G4S Sub-Contractor will provide workforce monitoring data in accordance with paragraph 3 (and sub paragraphs) of this Appendix, within six (6) Months of the Commencement Date and annually thereafter.

2.4 G4S will consider and agree the submissions made by the G4S Sub-Contractor when complying with paragraph 2 (and sub paragraphs of paragraph 2) and paragraph 3 (and sub paragraphs of paragraph 3) of this Appendix. Any issues will be raised with the G4S Sub-Contractor by the Contract Manager acting on behalf of G4S. If an issue relates to a Sub-contractor, the G4S Sub-Contractor must raise and resolve the issue with the Sub-contractor. Once submissions are agreed by G4S the G4S Sub-Contractor will formally review, revise and resubmit all information required in paragraph 2.2 and paragraph 2.3 on an annual basis. Diversity and equality aspects will also be discussed jointly by G4S and the G4S Sub-Contractor as an on-going item at the Contract review meetings.

2.5 In delivering the Services, the G4S Sub-Contractor shall prepare the Diversity and Equality Delivery Plan which as a minimum includes:

(a) An overview of G4S Sub-Contractor and any Sub-contractor’s policy/policies and procedures for preventing unlawful discrimination and promoting equality of opportunity in respect of:

(i) Race

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(ii) Gender

(iii) Gender reassignment

(iv) Disability (v) Age (vi) Sexual orientation

(vii) Religion/Belief

(viii) Pregnancy and Maternity

(ix) Marriage and Civil Partnerships;

(b) An overview of G4S Sub-Contractor and any Sub-Contractor’s policy/policies and procedures covering:

(i) Harassment

(ii) Bullying

(iii) Victimisation

(iv) Recruitment procedures (v) Staff training and development

Full policy documents must be made available to G4S on request;

(c) Details of the way in which the above policy/policies and procedures are, or will be (and by when), communicated to the Staff;

(d) Details of what general diversity and equality related training has

been, or will be delivered (and by when), to Staff; (e) Details of what structure is already in place, or will be in place (and by

when) and what resources are, or will be (and by when), directed towards diversity and equality within the G4S Sub-Contractor and any Sub-Contractor’s organisation; and

(f) Details of any diversity and equality cases and tribunals (including

volumes and outcomes) relating to the G4S Sub-Contractor and any Sub-Contractors.

2.6 In delivering the Services, the G4S Sub-Contractor shall provide evidence, as

required below, within the Diversity and Equality Delivery Plan as detailed at paragraph 2.2 of this Appendix:

(a) Where a G4S Sub-Contractor is delivering Services to participants on behalf of G4S or Services to G4S’ staff, the G4S Sub-Contractor must provide written evidence that:

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(i) Equality Impact Assessments have been carried out in conjunction with G4S prior to the Services being delivered and will be carried out in the event of any changes to the Services, in accordance with equality legislation;

(ii) reasonable adjustments are made, as required by

equality legislation to make those Services accessible to disabled people and that in the case of Information Technology services, those services are in accordance with G4S’ standards;

(iii) all Staff have had appropriate training so that they

understand the duties required by equality legislation, and where Services are being delivered on behalf of G4S , the G4S Sub-Contractor shall provide evidence that Staff understand the duties not to discriminate and to promote equality, in accordance with equality legislation.

2.7 G4S may request further information and assurance relating to diversity and

equality at any point during the duration of the Contract.

3. Monitoring and Reporting

3.1 The G4S Sub-Contractor shall provide workforce monitoring data as detailed in paragraph 3.2 of this Appendix. A template for data collected in paragraphs 3.2, 3.3 and 3.4 will be provided by G4S. Completed templates for the G4S Sub-Contractor and each Sub-Contractor will be submitted by the G4S Sub-Contractor with the Diversity and Equality Delivery Plan within six (6) Months of the Commencement Date and annually thereafter. G4S is required to provide workforce monitoring data for the workforce involved in delivery of the Contract. Data relating to the wider G4S Sub-Contractor workforce and wider Sub-contractors workforce would however be well received by G4S. The G4S Sub-Contractors and any Sub-contractors are required to submit percentage figures only in response to paragraphs 3.2(a), 3.2(b) and 3.2(c).

3.2 The G4S Sub-Contractor shall (and shall procure that each Sub-Contractor shall) provide separate information detailing:

(a) the proportion of employees who are:

(i) female; and/or

(ii) disabled (iii) those who prefer not to state gender and/or disability

b) the proportion of Staff who in terms of ethnicity are:

White (i) white British; (ii) white Irish; (iii) of any other white background

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Mixed (iv) white and black Caribbean; (v) white and black African; (vi) white and Asian; (vii) of any other mixed background

Asian or Asian British (viii) Indian; (ix) Pakistani;

(ix) Bangladeshi; (xi) of any other Asian background

Black or Black British (xii) Caribbean; (xiii) African;

(xiv) of any other Black background

Chinese or other ethnic group (xiv) Chinese; (xvi) of any other ethnic group

Prefer not to state (xvii) Prefer not to state ethnicity

For the avoidance of doubt, the seventeen (17) percentage figures submitted under categories i) to xvii) of this paragraph 3.2(b) (in each template in respect of the G4S Sub-Contractor’s employees and each Sub-contractors employees) should total one hundred percent (100%).

(c) The G4S Sub-Contractor will provide details of the proportion of its Sub-Contractors that are:

(i) small to medium sized enterprises (meaning enterprises with less than two hundred and fifty (250) employees and a maximum annual turnover of forty (40) million pounds);

(ii) ethnic minority enterprises (in each case meaning an

enterprise fifty one percent (51%) or more of which is owned by members of one (1) or more ethnic minority groups, or, if there are few owners, where at least fifty percent (50%) of the owners are members of one (1) or more ethnic minority groups). For this purpose, ethnic minority groups means ethnic groups other than White as referred to at paragraph 3.2(b) of this Appendix: and

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(iii) black ethnic minority enterprises (in each case meaning

an enterprise fifty one percent (51%) or more of which is owned by members of the Black or Black British ethnic group, or, if there are few owners, where at least fifty percent (50%) of the owners are members of the Black or Black British ethnic group). For this purpose, the Black or Black British ethnic group has the meaning referred to at categories xii) to xiv) in paragraph 3.2(b) of this Appendix.

For the avoidance of doubt, any given G4S Sub-Contractor may fall into one (1), two (2) or all of the categories i) to iii) listed in paragraph 3.2(c) of this Appendix, depending on its composition.

3.3 The G4S Sub-Contractor and any Sub-Contractors will compare their figures, in all categories listed in paragraphs 3.2(a), 3.2(b) and 3.2(c) of this Appendix, and provide (where possible) comparisons against any official national/regional statistics that are publicly available.

3.4 The G4S Sub-Contractor shall (and shall procure that each Sub-Contractor shall) provide evidence of activities undertaken, or planned, in order to try and improve their current position in the categories detailed in paragraphs 3.2(a), 3.2(b) and 3.2(c) of this Appendix.

3.5 The G4S Sub-Contractor shall (and shall procure that each Sub-Contractor shall) at all times comply with the requirements of the DPA in the collection and reporting of the information to G4S.

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APPENDIX 3

NOT USED

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APPENDIX 4

INFORMATION REQUIREMENTS

The G4S Sub-Contractor shall supply to G4S (in the format, and to the timescales, specified by the DWP and/or G4S) such information as G4S shall from time to time require which shall include (but shall not be limited to):-

Management Information Required Frequency/Date Required

Full and final Security Plan in accordance with Appendix 1

Within ten (10) Working Days after the Commencement Date of the Contract and reviewed at least annually thereafter.

Sustainable Development Policy Statement & Sustainable Development Plan in accordance with Appendix 5

Within six (6) Months of the Commencement Date and at least annually thereafter.

Diversity & Equality Delivery Plan in accordance with Appendix 2

Within six (6) Months of the Commencement Date and at least annually thereafter.

Workforce Monitoring Declaration in accordance with Appendix 2

Within six (6) Months of the Commencement Date and at least annually thereafter.

Apprenticeships & Skills Report in accordance with Appendix 6

Within six (6) Months of the Commencement Date and written updates on a quarterly basis thereafter.

HMG Baseline Personnel Security Standard - Provider’s Declaration see HMG Baseline Personnel Security Standard - A Guide for DWP Contractors

Within four (4) weeks of the Commencement Date and submitted for each calendar year thereafter within one Month of the end of each calendar year (i.e. by 31st January for year ending 31st December)

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APPENDIX 5

SUSTAINABLE DEVELOPMENT REQUIREMENTS

1. General

1.1 The G4S Sub-Contractor acknowledges that G4S must at all times be seen to be actively promoting Sustainable Development.

1.2 In delivering the Services, the G4S Sub-Contractor shall (and shall procure

that each Sub-Contractor shall) assist and cooperate with the G4S, by fully complying with the requirements of this Appendix.

2. Compliance

2.1 The G4S Sub-Contractor shall produce a Sustainable Development Policy Statement and Sustainable Development Plan in accordance with paragraphs 2.2 and 2.3 of this Appendix, within six (6) Months of the Commencement Date and annually thereafter. The Sustainable Development Policy Statement and Sustainable Development Plan must be specific to the Contract and include all Sub-contractors involved in delivery of the Contract. The G4S Sub-Contractor must obtain the required information from Sub-Contractors and then collate and submit as stated above.

2.2 In delivering the Services, the G4S Sub-Contractor shall prepare a Sustainable Development Policy Statement giving, for each organisation involved in delivery of the Contract:

(a) full assurance of waste disposal by a registered waste collector in accordance with current government regulations; and

(b) full assurance of the observation of Waste Electrical and Electronic

Equipment (WEEE) regulations.

2.3 In delivering the Services, the G4S Sub-Contractor shall prepare a Sustainable Development Plan which as a minimum, detail how each organisation involved in delivery of the Contract will:

(a) minimise waste produced and promote recycling; (b) minimise energy consumption; (c) minimise use of transport and promote use of public transport where

transport is unavoidable. Also required for each organisation are: (d) baseline assessment of current position in terms of waste

minimisation, recycling and energy consumption (energy consumption only required if current energy usage is available to organisations);

(e) annual estimates of the progress of Sustainable Development actions; (f) details of how Staff awareness of sustainability will be increased in

line with the Sustainable Development Plan.

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APPENDIX 6

APPRENTICESHIPS AND SKILLS REQUIREMENTS 1. General

1.1 Government is committed to addressing skills issues and promoting training opportunities through procurement, to maximise the potential for improvements provided by its considerable spend.

1.2 In order to support and drive economic growth, the Government announced that it has prioritised the key policy agendas to be promoted through public procurement. Supporting apprenticeships, skills and the fight against youth unemployment is one of these ‘Policy through Procurement’ priorities on which Departments must now focus.

1.3 The G4S Sub-Contractor acknowledges that G4S is required to support the above apprenticeships and skills aims and targets.

1.4 In delivering the Services, the G4S Sub-Contractor shall (and shall procure that each Sub-Contractor shall) assist and cooperate with G4S by fully complying with the requirements of this Appendix.

2. Compliance

2.1 The G4S Sub-Contractor shall (and shall procure that each Sub-Contractor shall take all reasonable steps to employ apprentices, and report to G4S the numbers of apprentices employed and wider skills training provided, during delivery of the Services.

2.2 The G4S Sub-Contractor shall (and shall procure that each Sub-Contractor

shall) take all reasonable steps to ensure that five percent (5%) of their employees are on a formal apprenticeship programme. This can include administration and support staff.

2.3 The G4S Sub-Contractor shall (and shall procure that each Sub-Contractor

shall) make available to employees’ information about the Government’s Apprenticeship Programme and wider skills opportunities.

2.4 The G4S Sub-Contractor shall (and shall procure that each Sub-Contractor

shall provide any appropriate further skills training opportunities for employees involved in delivery of the Contract.

2.5 The G4S Sub-Contractor will produce an Apprenticeships and Skills Report in

accordance with paragraph 3 (and sub-paragraphs) of this Appendix. 3. Monitoring and reporting

3.1 The G4S Sub-Contractor shall provide an Apprenticeships and Skills Report within six (6) Months of the Commencement Date and annually thereafter. The Apprenticeships and Skills Report must be specific to the Contract and include details for all Sub-Contractors involved in delivery of the Contract. The G4S Sub-Contractor must obtain the required information from Sub-

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Contractors and collate and submit an Apprenticeships and Skills Report that relates specifically to the Contract.

The Apprenticeships and Skills Report will include:

(a) the number of Staff during the reporting period involved in delivery of

the Contract, including administration and support staff; (b) the number of existing apprentices involved in the delivery of the

Contract; (c) the number of new starts on apprenticeships initiated as a result of

delivery of the Contract; (d) if applicable, a robust explanation as to why it is not possible to meet

the five percent (5%) target. (It may be that use of apprentices is not possible or appropriate in delivery of the Services);

(e) action being taken to improve the take up of apprenticeships. These

could include issuing leaflets on apprenticeships to eligible existing staff, advertising apprenticeship vacancies with local Jobcentre Plus, schools and colleges, offering apprenticeships in administration/support roles or seeking advice from the National Apprenticeship Service; and

(f) other training/skills development being undertaken by staff involved in

delivery of the Contract including:

(i) Work experience placements for 14 to 16 year olds

(ii) Work experience/work trial placements for other ages

(iii) Student sandwich/gap year placements

(iv) Graduate placements

(v) Vocational training

(vi) Basic skills training

(vii) On site training provision/facilities.

3.2 The G4S Sub-Contractor shall procure that each Sub-Contractor shall ensure at all times that they comply with the requirements of the DPA in the collection and reporting of the information to G4S.

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APPENDIX 7

HUMAN RESOURCES 1. Recruitment

The G4S Sub-Contractor shall ensure that they recruit and retain appropriately skilled Staff through:

a. having role profiles and job specifications for each position;

b. completing comprehensive and fair recruitment processes;

c. providing a full induction;

d. delivering regular performance reviews for all Staff with an ongoing

development plan;

e. producing training plans for each Staff member including: what training; when

it will be delivered; who will deliver the training; the format of the training; what

the training will achieve; and how the success of the training will be

measured;

f. providing Staff with regular updates of legislation changes, employment law

and any benefit regime; and

g. updates of best practice within and external to the welfare-to-work industry.

G4S requires evidence of these activities during audits and as part of our ongoing approach to continuous improvement.

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APPENDIX 8

PAYMENT REQUIREMENTS

Definitions “Allotted Time” means a continuous time period, starting at the point of the CWP

referral. From this point providers will have 30 weeks to deliver their service requirements and achieve completion outcome fees. “CWP Fees” means the Start Fee, the Job Outcome Fee, the Short Completion Outcome Fee and the Long Completion Outcome Fee. “CWP Start” shall have the meaning ascribed in the Contractor Guidance. “Job Outcome” shall have the meaning ascribed in the Contractor Guidance. “Job Outcome Fee” means the fee payable by G4S to the G4S Sub-Contractor on achievement of a Job Outcome and which shall be payable in accordance with the requirements of this Appendix 8. “Job Start” shall have the meaning ascribed in the Contractor Guidance. “Long Completion Outcome Fee” means the fee the G4S Sub-Contractor is eligible to claim once a Participant has completed between 22 and 26 weeks of work placement and/or employment as further described in the Contractor and Compliance Guidance. “Maximum Volume Cap” means the maximum number of Starts, Short Outcomes, Long Outcomes and Job Outcomes as specified in Appendix 8. “Off-Benefit” shall have the meaning ascribed in the Contractor Guidance. “Short Completion Outcome Fee” means the fee the G4S Sub-Contractor is eligible to claim once a Participant has completed between 12 and 21 weeks of work placement and/or employment as further described in the Contractor and Compliance Guidance. “Start Fee” means the fee the G4S Sub-Contractor is eligible to claim once the Participant has achieved a CWP Start which has been recorded on the G4S IT system, as further described in the Contractor and G4S Compliance Guidance.

1. Charges on Participants The G4S Sub-contractors or its agents shall not levy any charge on Participants in respect of goods or services provided under this contract except as expressly permitted in advance and in writing by G4S.

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2. Additional Costs and Value Added Tax Any additional or unforeseen costs incurred by the G4S Sub-Contractor in delivering the Provision shall be borne solely by the G4S Sub-Contractor.

Value Added Tax

2.1 Appendix 9 (Payment Profile) details the Fees exclusive of any applicable Value Added Tax (VAT).

2.2 Payment from G4S to the G4S Sub-Contractor shall be by a Her Majesty's Revenue and Customs (“HMRC”) approved self-billing process. The G4S Sub-Contractor hereby agrees that for the duration of the Contract, there will be a self-billing process in situ. The self-billing agreement included at the end of this Appendix shall be in place for the term of this Contract. This agreement needs to be signed and the VAT number confirmed in this agreement. G4S Sub-Contractor shall be paid by BACS transfer, generated by G4S’s internal accounting system, in response to appropriate system activity. G4S shall issue VAT invoices and it is the responsibility of the G4S Sub-Contractor to determine the correct VAT rate is charged. It remains the responsibility of the G4S Sub-Contractor to accurately account for and pay any VAT included in the payments received from G4S to HMRC.

2.3 If the VAT status of the G4S Sub-Contractor changes at any time during the delivery of the Services the G4S Sub-Contractor shall notify G4S immediately and in any case within 24 hours.

3. Claims for Payment 3.1 G4S shall pay the CWP Fees to the G4S-Sub-Contractor in accordance with Appendix 8 and Appendix 9, via a self-billing process approved by Her Majesty’s Revenue and Customs. 3.2 The G4S Sub-Contractor shall input such information as G4S specifies in the G4S Compliance Guides and DWP Contractor Guidance (including details of CWP Starts, Job Outcome Fees, Short Completion Outcome Fees and Long Completion Outcome Fees) onto the G4S IT System in the format specified by G4S in the Contractor Guidance. 3.3 Subject to the G4S Sub-Contractor inputting such information onto the G4S IT System as G4S specifies in the Compliance Guides and DWP Contractor Guidance (and in the format specified), Starts, Job Outcome Fees, Short Completion Outcome Fees and Long Completion Outcome Fees) will be generated in accordance with the provisions of Appendix 8. 3.4 NOT USED 3.5 Payment of CWP Fees will be made at the rates detailed in Appendix 9. G4S may at its discretion require the G4S Sub-Contractor to provide any appropriate supporting information it considers necessary before making payment. 3.6 G4S shall pay the CWP Fees within thirty (30) calendar days of an eligible CWP Fee being paid by DWP to G4S. Such outcomes will be as notified by the G4S Sub-Contractor via the G4S IT System as set out in this Appendix 8. Payment will be

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made at the rate applicable as specified in Appendix 9. Payment of CWP Fees will only be made to G4S Sub-Contractors, subsequent to G4S being in receipt of payments from DWP. In the event that the DWP make any deductions to the CWP Fees payable, G4S will apply the same deductions to the G4S Sub-Contractor as applicable with immediate effect. 3.7 If the G4S Sub-Contractor fails to comply with Clause 3.2 of Appendix 8, fails to input information onto the G4S IT System in the prescribed manner or fails to submit the appropriate supporting information when necessary, G4S shall not be in breach of this Contract if it fails to make payment within thirty (30) calendar days of the payment becoming due provided that G4S has not unnecessarily delayed payment of the relevant claim. 3.8 Details of the G4S Sub-Contractor’s bank account and address must be notified to G4S via email request and/or the supplier forms issued by G4S Finance. G4S shall send notifications of payments to that address. 3.9 Where the G4S Sub-Contractor enters into a sub-contract for the purpose of performing its obligations under the Contract, it shall ensure that a provision is included in such a sub-contract which requires payment to be made of all sums due by the G4S Sub-Contractor to the Sub-contractor within a specified period not exceeding thirty (30) days from receipt of payment from G4S. 3.10 G4S reserves the right to validate the outcomes submitted by the G4S Sub-Contractor prior to notifying DWP of the outcome. Such validation and compliance checks will be as specified in the G4S Compliance Guides and Contractor Guidance and additional information provided by G4S. Where there has been consistent failure in the quality of outcomes claimed, G4S will extrapolate the failure rate to withhold a percentage of the claims made in month, until such time that the quality requirements are fully met. 3.11 Interruption of Service: If there is at any time an interruption in the delivery of the Services as a result of a Default on the part of the G4S Sub-Contractor, G4S shall not be liable for payment of any Fees which relate to such period of interruption caused by Default by the G4S Sub-Contractor.

4. Methods of Payment 4.1 G4S reserves the right to set and/or alter, at its absolute discretion, the method of payment. All payments of Fees are conditional upon the G4S Sub-Contractor providing the Services in accordance with the terms of the Contract. 4.2 Payments are made on the condition that the G4S Sub-Contractor’s entitlement to such payments can be verified on request by the production of the records required under this Contract (including as specified in the G4S Compliance and Contractor Guidance). G4S shall, acting reasonably, be entitled to assume, in the absence of such records, or of any evidence which G4S or DWP may reasonably decide to accept in substitution, that such delivery of the Services (“Unsupported Services”) has not taken place. G4S shall be entitled to recover any and all sums paid in respect of such Unsupported Services from the G4S Sub-Contractor and the G4S Sub-Contractor shall repay such sums on demand, via self-billing process or by any other means adopted by G4S.

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4.3 Without prejudice to the clauses in Appendix 8, final claims in respect of all CWP Fees must be submitted by the date stipulated by G4S in the Compliance Guides and DWP Contractor Guidance. Any claims submitted after this date will not be paid.

4.4 Provided all previous claims have been paid (and subject to the provisions of this Contract and any antecedent breach), G4S shall have no further liability to make payment of any kind to the G4S Sub-Contractor once the final claims have been paid.

5. Types of Payment Job Outcome Fee 5.1 The total Job Outcome Fees payable shall be subject to the Maximum Volume Cap (“MVC”) set out in Appendix 9, notwithstanding the total number of valid Job Outcomes achieved by the G4S Sub-Contractor. Once this MVC has been reached, no further Job Outcome Fees shall be payable. G4S reserves the right to revise the MVC, pursuant to Appendix 10 Part C clause 2. 5.2 DWP will validate job outcome payments on a regular basis by conducting a series of post payment checks. Before payment of any Job Outcome Fee by DWP to G4S, the DWP shall undertake a check(s) to verify that the Participant is Off-Benefit.

5.3 Where the check(s) undertaken by the DWP pursuant to Clause 5.2 of Appendix 8 confirms that the Participant is not Off-Benefit, the DWP may (but shall not be obliged to) contact the Participant and/or the Participant’s employer to verify that the Participant is Off-Benefit and in employment. The DWP shall be entitled to reject any claims for payment made by the G4S Sub-Contractor which fail the check(s) undertaken by the DWP pursuant to Clause 5.2 of Appendix 8 without undertaking any further check(s). 5.4 Where the check(s) undertaken by the DWP pursuant to Clause 5.2 of Appendix 8 confirms that the Participant is not Off-Benefit, and the DWP elects to undertake further check(s) as set out in Clause 5.3 of Appendix 8 but:-

(a) the DWP is unable to contact the Participant and/or the Participant’s employer for any reason; and/or

(b) the Participant and/or the Participant’s employer fail to provide sufficient evidence to satisfy DWP that the Participant is Off-Benefit and in employment, DWP shall reject the claim for payment by the G4S Sub-Contractor.

5.5 After payment of any Job Outcome Fee by DWP to the G4S, DWP may check a representative sample of the Job Outcome Fees (which, for the avoidance of doubt, shall have passed the Off-Benefit check(s) undertaken by DWP pursuant to Clause 5.2 of Appendix 8) claimed by the G4S in a period to be specified and notified by DWP to the G4S and hereinafter being referred to as the “claim period”, to verify that the Participants that are the subject of such claims are in employment and that all the relevant qualifying criteria and requirements have been satisfied. 5.6 In carrying out a sample check pursuant to Clause 5.5 of Appendix 8, DWP may (but shall not be obliged to):-

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(a) carry out checks of data pertaining to the Participant arising out of or in connection with the Contract against data held by her Majesty’s Revenue and Customs and/or

(b) contact the Participant, and/or (c) contact the Participant’s employer

5.7 For the avoidance of doubt, any sample of claims used to undertake a sample check pursuant to Clause 5.5 of Appendix 8 shall be selected by DWP on a random basis. 5.8 DWP’s Extrapolation Checks: If, following a sample check undertaken by DWP pursuant to Clause 5.5 of Appendix 8 (in the sole opinion of DWP) DWP finds an error or over-claim in the sample, DWP shall be entitled to:-

(a) recover in full the amount or value of all such errors or over-claims; (b) assume that the same percentage of monies overpaid have been made in

respect of all of the Job Outcome Fees claimed by G4S in the Claim Period (which, for the avoidance of doubt, shall have passed the Off-Benefit check(s) undertaken by DWP pursuant to Clause 5.2 of Appendix 8 to produce an error rate (the “Error Rate”);

(c) extrapolate the Error Rate across all of the Job Outcome Fees claimed by G4S in the Claim Period (which for the avoidance of doubt shall have passed the Off-Benefit check(s) undertaken by DWP pursuant to Clause 5.2 of Appendix 8 to produce an aggregate value of monies overpaid (the “Aggregate Error Amount”);

(d) recover in full a sum equal to the Aggregate Error Amount less than the sum of any monies recovered by DWP pursuant to Clause 5.8 (a) of Appendix 8; and

(e) undertake a check of all Completion Outcome Fees claimed by G4S which relate to a Job Outcome Fee in respect of which (as a result of the sample check undertaken by DWP pursuant to Clause 5.5 of Appendix 8) DWP has identified an error or over-claim; and

(f) where, following a check of Completion Outcome Fee claims pursuant to Clause 5.8 (e) of Appendix 8, DWP finds an error or over-claim in any Completion Outcome Fee, recover in full from the amount of value of all such errors or over-claims.

(g) Any recovery of monies by the DWP from G4S in accordance with 5.8 above, which is in the sole opinion of G4S a result of a G4S Sub-Contractor error, will be recoverable from the G4S Sub-Contractor immediately.

(h) The recovery of any such monies will be deducted via the self-billing process immediately upon notification to G4S by DWP.

Start Fee

5.9 The total Start Fees payable shall be subject to the MVC set out in Appendix 9. Once this MVC has been reached, no further Start Fees shall be payable. G4S reserves the right to revise this MVC, pursuant to Appendix 10 Part C Clause 2. 5.10 DWP may undertake a sample check(s) to verify that the qualifying criteria and requirements for a Start Fee as set out in Appendix 8 (Payment Requirements) and the Specification have been met.

5.11 The G4S Sub-Contractor will be eligible to claim a Start Fee once the participant has achieved a CWP Start and this CWP Start has been recorded on the G4S IT System. Only one Start Fee will be payable for each participant per period of Allotted

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Time. In order to record a CWP Start, the G4S Sub-Contractor must ensure a Participant has participated in an initial engagement meeting and subsequently starts a work placement (or starts employment). 5.12 DWP’s Extrapolation Checks: If, following a sample check undertaken by DWP pursuant to Clause 5.9 of Appendix 8, (in the sole opinion of DWP) DWP finds an error or over-claim in the sample, the DWP shall be entitled to:-

(a) recover in full the amount or value of all such errors or over-claims; (b) assume that the same percentage of monies overpaid have been

made in respect of all of the Start Fees claimed in the Claim Period undertaken by DWP pursuant to Clause 5.9 of Appendix 8 to produce an error rate (the “Error Rate”);

(c) extrapolate the Error Rate across all of the Start Fees claimed by G4S in the Claim Period undertaken by DWP pursuant to Clause 5.9 of Appendix 8 to produce an aggregate value of monies overpaid (the “Aggregate Error Amount”);

(d) recover in full a sum equal to the Aggregate Error Amount less than the sum of any monies recovered by DWP pursuant to Clause 5.12 (a) of Appendix 8; and;

(e) undertake a check of all the Start Fees claimed by the G4S Sub-Contractor which relate to the Start Fees in respect of which (as a result of the sample check undertaken by DWP pursuant to Clause 5.9 of Appendix 8) DWP has identified an error or over-claim; and

(f) where, following a check of the Start Fees pursuant to Clause 5.12 (e) of Appendix 8, DWP finds an error or over-claim in any of the Start Fees, recover in full from the G4S the amount of value of all such errors or over-claims

(g) Any recovery of monies by the DWP from G4S in accordance with 5.8 above, which is in the sole opinion of G4S as a result of a G4S Sub-Contractor error, will be recoverable from the G4S Sub-Contractor immediately.

(f) The recovery of any such monies will be deducted via the self-billing process immediately upon notification to G4S by DWP.

Short Completion Outcome Fees and Long Completion Outcome Fees

5.13 The total Short and Long Completion Outcome Fees payable shall be subject to the MVC set out in Appendix 9. Once the MVC has been reached, no further Short and Long Completion Outcome Fees shall be payable. G4S reserves the right to revise the MVC, pursuant to Appendix 10 Part C clause 2. 5.14 DWP will independently validate completion fees on a regular basis by conducting pre-payment checks. Before payment of any Short Completion Outcome Fee or Long Completion Outcome Fee (a “Completion Outcome Fee”) by DWP, DWP will undertake a check(s) to verify that the qualifying criteria and requirements for the relevant Completion Outcome Fee as set out in Appendix 8 (Payment Requirements), G4S Compliance Guides, Specification, DWP Contractor Guidance and memos have been met.

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5.15 DWP may contact the Participant and/or the Participant’s work experience host organisation and/or, where applicable, the Participant’s employer to validate that the qualifying criteria and requirements have been met. 5.16 For the avoidance of doubt, any sample of claims used by DWP to undertake a sample check pursuant to Clause 5.14 of Appendix 8, shall be selected by DWP on a random basis.

5.17 DWP’s Extrapolation Checks: If, following a sample check undertaken by DWP pursuant to Clause 5.14 of Appendix 8, (in the sole opinion of DWP) DWP finds an error or over-claim in the sample, DWP shall be entitled to:-

(a) recover in full the amount or value of all such errors or over-claims; (b) assume that the same percentage of monies overpaid have been

made in respect of all of the Short Completion Outcome Fees and/or Long Completion Outcome Fees claimed in the Claim Period undertaken by DWP pursuant to Clause 5.14 of Appendix 8 to produce an error rate (the “Error Rate”);

(c) extrapolate the Error Rate across all of the Short Completion Outcome Fees and/or Long Completion Outcome Fees claimed in the Claim Period undertaken by DWP pursuant to Clause 5.14 of Appendix 8 to produce an aggregate value of monies overpaid (the “Aggregate Error Amount”);

(d) recover in full a sum equal to the Aggregate Error Amount less than the sum of any monies recovered by DWP pursuant to Clause 5.17 (a) of Appendix 8; and;

(e) undertake a check of all the Short Completion Outcome Fees and/or Long Completion Outcome Fees claimed by G4S which relate to the Short Completion Outcome Fees and/or Long Completion Outcome Fees in respect of which (as a result of the sample check undertaken by DWP pursuant to Clause 5.16 of Appendix 8) DWP has identified an error or over-claim; and

(f) where, following a check of the Short Completion Outcome Fees and/or Long Completion Outcome Fees claims pursuant to Clause 5.17 (e) of Appendix 8, DWP finds an error or over-claim in any of Short Completion Outcome Fees and/or Long Completion Outcome Fees, recover in full the amount of value of all such errors or over-claims.

(g) Any recovery of monies by the DWP from G4S in accordance with 5.8 above, which is in the sole opinion of G4S as a result of a G4S Sub-Contractor error, will be recoverable from the G4S Sub-Contractor immediately.

(f) The recovery of any such monies will be deducted via the self-billing process immediately upon notification to G4S by DWP.

5.18 For avoidance of doubt, G4S rights in this Clause 5 of Appendix 8 shall be without prejudice to any other rights or remedies that G4S have under the Contract (including for the avoidance of doubt, any rights of set-off pursuant to Clause 3 of the Call-Off Terms and Conditions for Community Work Placements (Recovery of Sums Due). Further details will be provided in G4S Compliance Guides, DWP Contractor Guidance and Memos.

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6. Third Party Revenue The G4S Sub-Contractor may not obtain any third party revenue, income or credit based on the service, goods and / or Copyright Works delivered under this Contract without the express prior written agreement of G4S.

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APPENDIX 9

PAYMENT PROFILE

For the performance of the Services, the G4S Sub-Contractor shall be paid the Contract Price calculated using the prices and rates entered in this Appendix.

Portsmouth Council

Maximum Volumes

% rate applied (offer)

Fee £

Fee Cap £

% of Contract

Value Cap

Start Fee

879 100% £275.00 £241,725.00

20%

Short

Completion Outcome Fee

703 80% £343.75 £241,725.00

20%

Long

Completion Outcome Fee

527 60% £687.50 £362,587.50

30%

Job Outcome

Fee 176 20% £2,062.50 £362,587.50

30%

Total

Contract Value

£1,208,625.00

1 Payment Profile

1.1 Fees indicated above will be excluding VAT 1.2 Where DWP imposes a Contract Value Cap, this will be applied to the G4S Sub-

Contractors from such date. 1.3 The MVC and Contract Value Cap indicated above will apply for the Contract

Period, unless G4S revises this pursuant to Appendix 10 Part C clause 2. or DWP notifies G4S of a change.

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APPENDIX 10 CONTRACT PERFORMANCE

The G4S Sub-Contractor shall ensure they meet or exceed the Minimum Service Levels, Minimum Operational Requirements and Minimum Performance Levels from the Contract Commencement Date. The G4S Sub-Contractor must also abide by the DWP Contractor Guidance and any subsequent updates or Live Running Memos that amend or enhance that guidance.

PART A: MINIMUM SERVICE LEVELS

G4S has committed to delivering a number of service delivery standards to DWP, which we expect from all G4S Sub-Contractors (and each Sub-Contractor for all Participants.

G4S Sub-Contractor Services

Every Participant will have an individually named Personal Advisor during their time on Community Work Placements

G4S Sub-Contractors to ensure they have the facilities to accept a warm handover from JCP, including a named contact

G4S Sub-Contractors will ensure that a participant attends an initial engagement meeting within 10 working days of referral, or appropriate DMA is immediately raised and evidenced (within 24 hours of failure to comply).

Every participant will have a placement sourced within 15 days of referral.

G4S Sub-Contractors ensure that the participant starts a work placement or moves into employment (the contractual target is that this takes place within 15 working days of referral), or appropriate DMA is immediately raised and evidenced (within 24 hours of failure to comply).

G4S Sub-Contractors record a start (or a Fail to Attend/ Start) in G4S IT System within 15 working days of the CWP referral.

G4S Sub-Contractors ensure that Provider-led job search and/or other work-related activity is delivered for a minimum of 30 hours per week for compliant participants who, do not start CWP (e.g. due to insufficient available placements), or are between placements.

G4S Sub-Contractors immediately (within 24 hours of failure to comply) raising appropriate DMA, where a participant ‘Fails To Attend’ their Initial Engagement Meeting or ‘Fails To Start’ their work placement as mandated.

G4S Sub-Contractors recording in G4S IT System, where a participant ‘Fails To Attend’ their Initial Engagement Meeting or ‘Fails To Start’ their work placement as mandated, within 24 hours of the failure.

G4S Sub-Contractors ensure that a contact telephone number is supplied for the participant to use to contact the Placement Brokers while they are on provision.

G4S Sub-Contractors ensure participants participate in 30 hours work placement provision per week (unless participation restrictions apply).

G4S Sub-Contractors ensure participants receive a minimum of 4 hours provider-led job search per week from referral date. This must not exceed 10 hours.

G4S Sub-Contractors ensure that where a participant has started CWP and subsequently fails to comply as mandated, appropriate DMA is immediately (within 24 hours of failure to comply) raised and evidenced.

G4S Sub-Contractors ensure the development and delivery (to the participant) of a completed, participant specific, participant portfolio as outlined in G4S Compliance and Contractor Guidance.

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G4S Sub-Contractors ensure the completion and secure delivery to JCP of participant exit feedback within 10 working days of request from JCP.

G4S Sub-Contractors to have effective tracking systems in place to monitor all Participants In Work to achieve Job Outcomes target as prescribed in Appendix 10 Part C

G4S Sub-Contractors ensure they meet the requirement to keep documentation to support the work placement(s) start date and future attendance - DWP and/ or auditors, including National Audit Office (NAO) and (in England) ESF auditors can request this documentation at any time.

Adhere to all ESF requirements, including the retention of relevant evidence documentation until 31st December 2030

Work Placement Minimum Standards

G4S Sub-Contractors ensure that the provision environment is conducive with achieving the desired outcomes for the participant and providers must ensure minimum Health & Safety standards, as laid down in legislation, are met at all times.

G4S Sub-Contractors ensure that work placements are, of benefit to the community, additional to existing or expected vacancies and that all principles detailed regarding quality of work placements are met and outlines on the G4S Compliance and Contractor Guidance.

Every Participant will have an individually named supervisor within their placement host.

Every Participant will have a Placement plan in accordance with the G4S guidance, which must include the date of the first review.

Every Participant will be supported to identify a Realistic Job Goal (“RJG”) to be included in their Placement Plan.

Every Participant will have an induction on or prior to the first day of their placement.

G4S Sub-Contractors ensure no more than 20% of completed work placement weeks involve participants undertaking retail duties within charity shops.

G4S Sub-Contractors to ensure you liaise with your Supply Chain Manager before using private sector companies to deliver Work Placements (to confirm a work placement is appropriate both in terms of community benefit and displacement of what would otherwise be paid economic jobs).

PART B: OPERATIONAL REQUIREMENTS

1. The G4S Sub-Contractor shall ensure:

a. that every Participant is able to attend a face-to-face appointment by making

any reasonable adjustments for any Participant with a disability under the

Equality Act and/or other relevant disability legislation;

b. they maintain Minimum Delivery Performance Levels as detailed in Part C of

Appendix 10, despite any fluctuations in flows;

c. that all interventions with Participants, Referrals, Start, Attendance, Job

Starts, Job Outcomes, job drop-outs, Placement completion/non-completion,

are recorded on to G4S IT System in an appropriate and timely manner, as

detailed in the Acceptable Use Policy (Appendix 1, Annex 1), including as a

minimum:

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all mandatory Participant detail fields;

details of all Participant contact;

Individual Action Plans;

Placement Plans

Action Plan Reviews

Agreed support for Participant

Job search activity undertaken

Job details; and

Any change in circumstances to Participant

d. that an appropriate ratio of Managers to Personal Advisors and Placement

Officers and administrative support is maintained, which will be monitored as

part of the performance review process;

e. that they provide details of individual email addresses personal to each

member of Staff providing the Services, in order that we are able to

communicate securely with individuals as necessary; and

f. that they retain flexibility around opening hours and days in order to provide

appropriate access to the Services for Participants

2. The G4S Sub-Contractor shall ensure:

a. that they maintain a geographically appropriate presence across their delivery

area

b. the required resource is available to adhere to all aspects of the Contractor

Guidance and G4S compliance guides

c. each Participant will have an Initial Engagement Meeting with their Personal

Advisor within 2 weeks of the referral

d. all reasonable Participant travel costs are reimbursed

e. where required a Participant’s approved childcare is funded

3. The G4S Sub-Contractor shall ensure they:

a. provide a service to track all Participants’ progress throughout the CWP

Programme from engagement to completion;

b. track all Participants’ progress in placement and in work;

c. provide the first point of contact for Participants in work;

d. liaise with partner agencies and other G4S Sub-Contractors as necessary to

support Participant’s progress.

4. G4S requires G4S Sub-Contractors to have an effective ongoing Stakeholder

Engagement Plan throughout the life of the Contract including relationships with

local Jobcentre plus and Local Authorities.

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a) G4S requires G4S Sub-Contractors to have dedicated members of staff

(Placement Officers) who are responsible for the sourcing and securing of

placement opportunities on an ongoing basis throughout the contract life.

b) Each G4S Sub-Contractor will also produce a Placement Development Plan,

which will summarise all placement generating activity and outline clear

targets to deliver the expected outcomes. This will be reviewed and updated

on a monthly basis and signed off by the G4S Supply Chain Manager.

5. The responsibility of design of the CWP Programme delivery is left to the G4S

Sub-Contractor. With the exception of:

a. The G4S Sub-Contractor must abide by any Contractor Guidance and/or any

supplementary notices from DWP; and

b. as a result of supplementary notices or post contract go live, G4S reserves

the right to require the G4S Sub-Contractor to implement new process

requirements to improve service delivery or ensure compliance.

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PART C: MINIMUM DELIVERY PERORMANCE LEVELS

Minimum Performance Levels

Once the contract has gone live, G4S Sub-Contractors will be required to deliver to the following minimum performance levels:

100% of referred participants achieving either, a CWP Start, or have appropriate DMA activity initiated, with the CWP Start, Fail to Attend or Fail to Start recorded in G4S IT System within 15 working days of the CWP Referral.

Appropriate DMA is immediately raised and evidenced (within 24 hours of failure to comply as mandated for Initial Engagement Activity and Placement Start).

20% of CWP Starts being converted into Job Outcomes.

The performance offer for Short and Long Completion Outcomes being met. No more than 20% of completed work placement weeks involve participants undertaking retail duties within charity shops.

Start to Short Outcome

Start to Long Outcome

Start to Job Outcome

Cohort Target conversion rate*

80% 60% 20%

*G4S define ‘Cohort’ as a group of Participants who are referred to the CWP programme within the same calendar month. Within each Cohort we expect the Target conversion rate to be achieved by completion of the Allotted Time with the exception of Job Outcome (potentially week 58). The G4S Supply Chain Manager, in consultation with the G4S Contract Director, will provide each G4S Sub-Contractor with a breakdown of numerical monthly Performance Targets. The Performance Targets will be calculated by applying anticipated referral flows to the MDPL and will take account of previous Cohort performance. These Performance Targets will be distributed each quarter and reviewed as a minimum monthly, taking into account flows, macro-economic factors and any benefit regime change(s). Where the monthly Performance Targets cannot be agreed by the G4S Sub-Contractor and the G4S Supply Chain Manager, there is the opportunity to raise an appeal in writing within 5 working days of receipt to the G4S Contract Director. G4S will take reasonable steps to ensure that an agreement on Performance Targets is reached. Where this is not possible the G4S Sub-Contractor will be put on notice as failing to be compliant. Performance will be formally measured each month against G4S Sub-Contractor

targets, in each location in which they deliver. Performance will be compared to other

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G4S Sub-Contractor in the G4S Supply Chain within the Contract Package Area in a published league table 2. Withholding or Removal of Maximum Volumes

G4S shall be permitted to reduce the MVC in the following circumstances:

a. G4S is notified by the G4S Sub-Contractor that their total Participant Volume

level would be exceeded if further Participants were referred;

b. the G4S Sub-Contractor’s performance is unsatisfactory as Contract

Performance (as detailed in Appendix 10) is not being achieved;

c. there has been a Material Breach of the terms and conditions of this Contract;

d. there has been a Level 2 or Level 3 Service Failure;

e. Fraud or irregularity is suspected in the conduct of the G4S Sub-Contractor’s

business.

f. At its discretion with 3 month’s notice

G4S shall be permitted to increase the volume levels at any time during the Contract in agreement with the G4S Sub-contractor

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APPENDIX 11 Referrals & CWP Starts

Maximum CWP Starts: 879 End-end delivery of the Community Work Placements Service in Portsmouth, Fareham, Havant, Cosham, Gosport and Petersfield 1. General

DWP, and therefore G4S, are unable to guarantee: overall “Referral” (a participant referred from Jobcentre Plus) volumes;

a. the timing of Referrals; or,

b. the geographic spread of Referrals.

2. Generating and Maintaining Referral Volumes

G4S will set Referral targets on a quarterly basis. The Referral targets will reflect the predicted flow from JCP offices. G4S Sub-Contractors are responsible for maintaining the Referral volumes set in the Referral targets. This can be done by:

a. building close relationships with JCP(s);

b. maintaining a strong presence at their local JCP(s) to market JCP staff where

required.

3. Suspension of Referrals

The Referral allocation proportions may be suspended where: a. G4S notes that, or is notified by, the G4S Sub-Contractor that their total Participant caseload capacity would be exceeded if further Participants were referred; b. the G4S Sub-contractors’ performance is unsatisfactory as Contract Performance (as detailed in Appendix 10) is not being achieved; c. there has been a Material Breach of the terms and conditions of this Contract; d. Minimum Service Level and/or Minimum Delivery Levels are not all being met;

there has been a Level 2 or Level 3 Service Failure;

e. Fraud or irregularity is suspected in the conduct of the G4S Sub-Contractor’s

business and an investigation is currently being undertaken by the G4S Audit

Team.

Consequences of Referral Suspension

a. In the event that Referrals are suspended, G4S will reallocate suspended

Referrals to another G4S Sub-Contractor. These arrangements will remain in

place until the G4S Sub-Contractor satisfies G4S that the cause of Referral

suspension has been rectified.

b. Referrals will resume from the commencement of the month following

rectification. There will be no adjustment to future Referral volumes to

retrospectively correct the distribution of Referrals to a G4S Sub-Contractor

whose Referrals had been suspended.

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c. The Referral volumes may be permanently adjusted at review points and are

subject to achieving the Contract Performance as detailed in Appendix 10.

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APPENDIX 12 PERFORMANCE IMPROVEMENT PROCESS

1. General

The G4S Sub-Contractor will: a. communicate the G4S vision and objectives to their Staff;

b. cascade their Performance Targets to individual operations managers and

frontline staff;

c. use regular reports to hold each member of Staff responsible for their

achievement against their share of the Performance Targets;

d. manage under-performing Staff; and

e. recognise and reward over-performing Staff.

2. Performance Intervention

2.1 Where a G4S Sub-Contractor is aware that under-performance will occur and

where Contract Performance as detailed in Appendix 10 is not being achieved,

the G4S Sub-Contractor shall:

a. notify their G4S Supply Chain Manager at the earliest opportunity of any

Service Failure;

b. provide G4S with a Performance Improvement Plan (“PIP”) at the earliest

opportunity, or within 3 Working Days;

c. deploy all additional resources and take all remedial action that is necessary

to rectify or prevent Service Failure from recurring; and

d. implement, after consultation and approval of the G4S Supply Chain

Manager, the actions identified in the PIP.

2.2 The PIP must contain (but is not limited to):

a. a comprehensive outline of the Service Failure;

b. details of the circumstances leading to the Service Failure;

c. timeframes for rectification of the immediate situation;

d. timeframes to rectify contract performance in line with performance targets as

detailed in Appendix 10;

e. a comprehensive outline of how a reoccurrence of the Service Failure will be

avoided;

f. details of resource allocation to address the Service Failure;

g. any disciplinary actions to be taken to address staff performance failures;

h. implications on G4S Sub-Contractor staff training; and

i. G4S Sub-Contractor organisational changes or changes in reporting or

escalation procedures.

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3. Service Failure

Where the PIP does not rectify failures or prevent future Service Failures, G4S may instigate one of 4 levels of intervention depending on the severity of the underperformance or Service Failure: Level 1: The G4S Sub-Contractor misses their Performance Levels in one month or misses any Minimum Service Delivery Level or Minimum Operational Requirement. Where a Level 1 Service Failure occurs the G4S Sub-Contractor shall:

submit a PIP with their weekly report; and

augment their operations with the appropriate level of resource.

Level 2: The G4S Sub-Contractor misses their Performance Levels by more than 30% in one month, or under-performs by cumulatively over 2 consecutive months, or where Minimum Service Delivery Levels or Minimum Operational Requirements are missed consecutively for two (2) months or more in spite of PIP. Where a Level 2 Service Failure occurs the G4S Sub-Contractor shall:

submit a PIP in conjunction with and signed off by their internal Senior

Management Team (“SMT”) within three (3) Working Days; and

issue a schedule of activity and intervention which G4S agrees and signs off.

G4S can consider withholding Referral volumes as detailed in Appendix 11 on a Level 2 Service Failure. Level 3: The G4S Sub-Contractor continues to miss their Performance Targets and has been on PIPs continuously for a 3 month period. Where a Level 3 Service Failure occurs the G4S Sub-Contractor shall:

permit a G4S operations expert into their operations to agree a PIP in

conjunction with the SMT. This will also provide a phased schedule of support

with progressive and corrective actions. The G4S Sub-Contractor requiring

the intervention will pay all costs incurred.

comply with a request to remove specific Personal Advisors/Placement

Officers and/or managers/support staff from the CWP Programme.

G4S can withhold Referral volumes as detailed in Appendix 11 and transfer to another G4S Sub-Contractor at this stage. Level 4: The G4S Sub-Contractor fails to achieve their Performance Levels, where Level 1, 2 and 3 Service Failures have already been invoked and there is insufficient evidence of performance improvement. Where a Level 4 Service Failure occurs, G4S may terminate the Contract in whole or in part by giving notice to the G4S Sub-Contractor with immediate effect and without liability as outlined in the Contract. Depending on the circumstances for Contract termination, the G4S Sub-Contractor will either agree to a live caseload transfer or will agree to continually provide a contractually compliant service to existing Participants. Where Performance Targets are not met with these Participants the G4S Sub-Contractor will be subject to a financial penalty on all payment claims as outlined in the Contract. The PIP does not affect G4S’s right to serve notice and to terminate the Contract pursuant to any other termination rights under the Contract.

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APPENDIX 13 PART A: MONITORING REQUIREMENTS

1. Reviewing Contract Performance

The G4S Sub-Contractor shall work with G4S to establish and maintain an effective

and beneficial working relationship and to ensure the Contract is delivered to at least

the minimum required standard as specified in Appendix 10 (Contract Performance).

The G4S Sub-Contractor shall work with G4S to establish suitable administrative

arrangements for the effective management and performance monitoring of the

Contract. Arrangements shall include mechanisms for the Services of management

information, feedback to and from employers and Participants, change control

procedures and the prompt resolution of any problems.

G4S will agree with the G4S Sub-Contractor day-to-day relationship management,

contact points, communication flows and escalation procedures. Roles and

responsibilities will be documented and the personnel involved in managing the

relationship identified and suitably empowered.

G4S will monitor G4S Sub-Contractor performance at least monthly. G4S will apply a

situational approach to monitoring. Every three months (or any other period to be

notified as appropriate) G4S will undertake a contractual review and award a formal

risk rating to the G4S Sub-Contractor. The risk rating will be based on a number of

criteria including: performance against contractual targets; annual contract value; and

quality and continuous improvement activity. The risk rating will be used to inform the

frequency of subsequent G4S Sub-Contractor Performance Reviews and supporting

monitoring activity.

G4S will monitor the delivery of the G4S Sub-Contractor through: 1.1 analysis of Contract Performance (Appendix 10);

1.2 reports generated from the G4S IT system;

1.3 a tailored situational management plan, which will include the purpose and

frequency of meetings;

1.4 monthly performance review meetings with G4S Sub-Contractor managers

and with G4S Supply Chain Managers and/or G4S Contract Directors;

quarterly strategic performance review meeting with G4S Sub-Contractor

Directors, managers, G4S Supply Chain Managers and G4S Contract

Director

1.5 adhoc visits from G4S regional and central teams, review of paper files,

feedback from focus groups with Participants, speaking with employers and

meeting Advisors;

1.6 meetings with specific key staff of the G4S Sub–Contractor, sharing best

practice through joint management training opportunities across the supply

chain.

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G4S shall ensure that they give adequate notice to the G4S Sub-Contractor where their requests for visits, meetings, system access or reports could potentially cause an adverse effect on delivery. However, please see section 3 regarding unannounced audits by the G4S Compliance Team. G4S Sub-Contractor reviews may be undertaken formally or informally depending on

risk and any identified issues. Risk ratings will be communicated to the G4S Sub-

Contractor. The G4S Sub-Contractor will be expected to provide any additional

management information required by G4S to facilitate this process and arrange

where necessary access to any of its delivery locations, including those operated by

G4S Sub-Contractors.

The purpose of the G4S Sub-Contractor Performance Reviews is to encourage an

open and regular dialogue between the Parties with the purpose of ensuring that the

Services, including the standards and outputs specified, is being delivered

appropriately and to drive up the performance and quality of the Services. They will

encourage the Parties to review performance, discuss opportunities for continuous

improvement and raise and address any complaints or persistent problems

encountered with the Contract. Where issues cannot be immediately addressed, G4S

and the G4S Sub-Contractor will follow the Dispute Resolution Process detailed in

Clause 9.2.

The regular meetings between G4S and the G4S Sub-Contractor shall also cover, as

appropriate, resolving disputes and/or dealing with contractual breaches in

accordance with the Contract Periods and conditions of the Contract.

G4S shall monitor and review the performance and quality of the G4S Sub-

Contractor against the requirements set out in the Contract and within the overall

contract management approach as detailed above. Any improvements or actions

agreed between the Parties will form part of the continuous improvement activity

recorded in the Provider Development Plan that will be used to inform the annual

Self-Assessment.

The G4S Sub-Contractor will independently be expected to carry out self-assessment

and develop improvement action plans to continuously improve the quality of the

Services, including that delivered by Sub-Contractors. Where quality falls below

acceptable levels, the G4S Sub-Contractor will be expected to have suitable

escalation procedures in place and, in respect of sub-contracted Services, take

action where necessary to terminate the sub-contract.

2. Health & Safety Responsibilities of G4S Visiting Staff

G4S’s representatives shall visit the G4S Sub-Contractor and its G4S Sub-

Contractors for a variety of reasons. In the course of their normal duties such

representatives of G4S shall adopt an ‘eyes and ears' approach to monitoring health

and safety. In doing this G4S’s representatives shall not be conducting a health and

safety inspection, nor shall they be in a position to offer advice on whether something

is safe or not. Instead they shall approach this from the position of any lay person. If,

however, one of G4S’s representatives does notice something on which they require

assurance or clarification, they shall raise this with the G4S Sub-Contractor. In no

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event are G4S’s representatives to be seen as offering professional advice on health

and safety matters and as such, shall not be liable for any advice or comments or

otherwise given to the G4S Sub-Contractor or any omission to give such advice,

comments or otherwise.

3. G4S Quality and Compliance Team

The primary purpose of the Quality and Compliance team is to provide G4S with an

assurance that payments to G4S Sub-Contractors are in accordance with DWP

requirements that public funds are protected and that value for money has been

obtained.

Planning of visits by the G4S Quality and Compliance team to Placement Brokers

shall take account of the Services and the assessment of the risk attached to the

delivery of the Services, the majority of audits will be unannounced. The assessment

of risk shall follow an evaluation of the key, relevant systems adopted by the G4S

Sub-Contractor, supported by the results of testing undertaken.

The G4S Sub-Contractor shall have systems in place (depending on the Services

type) to:

3.1 detect and prevent duplicate claims;

3.2 submit accurate, valid, supported, claims;

3.3 monitor, record and manage lateness and all absences;

3.4 ensure that all the required evidence is collected (and submitted, where

appropriate) to support the claim;

3.5 carry out effective monitoring of Sub-Contractors;

3.6 detect Participants who have left the Services (“Leavers”) early to prevent

over claiming; and

3.7 respond to monitoring reports with an appropriate action plan.

4. Security Requirements

G4S will review the G4S Sub-Contractor Security Plan when submitted by the G4S

Sub-Contractor in accordance with Appendix 1 (Information Management and Data

Security), and at least annually thereafter.

5. Access

In all instances, the G4S Sub-Contractor shall co-operate and provide such

reasonable assistance as may be necessary to facilitate monitoring pursuant to this

Appendix. Failure to provide such reasonable assistance shall be deemed a "material

breach" for the purposes of Clause 8.2 (Termination on Default).

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PART B: MONITORING TEAMS

1. Monitoring Teams

Contract performance will be managed by a named G4S Supply Chain Manager

overseen by the G4S Contract Director.

G4S Head of Compliance and Monitoring Officers will support the Supply Chain

manager in monitoring the quality of service delivery as specified in Appendix 10.

The G4S Sub-Contractor will be required to appoint a named Contract Manager who

will cooperate with the G4S Supply Chain Manager to ensure that the Services are

delivered as specified in the Contract and that required standards and performance

levels are met.

2. Job Centre Plus

G4S Sub-Contractors will be expected to develop and maintain their own close

working relationship with local JCP managers and staff. The G4S Sub-Contractor

associated with each JCP office may be required to coordinate engagement to

facilitate ease of service for JCP.

G4S Sub-Contractors will be required to attend Provider Engagement Meetings (“PEM”) with JCP, DWP and other CWP G4S Sub-Contractors. The PEMs will focus on performance, delivery and participant experience. Strategic partners may also be invited to attend. These meetings will be used to develop good local working relationships with JCP and provide an opportunity to address, in collaboration, local operational delivery issues.

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APPENDIX 14

PARTICIPANT COMPLAINTS POLICY 1. Notification of a Complaint or Feedback

1.1 A complaint, or notification of a complaint, by a Participant, is received in the following ways:-

verbally;

in writing;

via email;

through a third party (e.g. Job Centre Plus);

by telephone.

1.2 Complainants are able to feedback or complain to:-

Job Centre Plus direct;

their Personal Advisor;

their G4S Subcontractor’s Operations Manager;

the G4S Regional Team;

the G4S Central Team;

the Independent Case Examiner (ICE).

Contact details for all of the above are provided in a variety of formats depending upon the individual’s circumstances e.g. Braille, large print, audio tape and in community languages such as Urdu, Bengali, Polish and Somali.

In the first instance, complaints will be investigated and responded to by the G4S Sub-Contractor directly. However, Participants will be able to complain directly to G4S if they wish. Where appropriate, complaints received in via the G4S regional or central teams will be de-escalated for initial investigation by the G4S Sub-Contractor locally.

Participants are notified of our complaints procedure at the Initial Engagement Meeting and the complaints procedure will be clearly advertised in local offices and in the placement packs.

2. Action to be taken upon receipt of a Mixed Complaint (against G4S Sub-Contractor and JobCentre Plus (“JCP”) 2.1 Method 2.1.1 If a Complainant raises this type of complaint with a G4S Sub-Contractor, this

should be highlighted to the G4S Regional Complaints Point of Contact (POC) and the G4S Sub-Contractor should liaise with JCP locally.

2.2 Ownership 2.2.1 Where JCP has ownership of a complaint, JCP will lead on responding to the

Complainant, and they may ask for a contribution from G4S or the G4S Sub-Contractor. If you are contacted by JCP regarding a complaint you should

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return any paperwork or contribution to a reply within stated timescales and at least within 5 working days.

3.0 Action to be taken upon receipt of a Complaint via the G4S Sub-Contractor 3.1 Method

3.1.1 Complaint delivered verbally, in-writing, via email, over the telephone or via a third party, such as JCP. In the first instance the complaint will be directed to the G4S Sub-Contractor, however, Complainants will be able to complain directly to G4S if they wish.

3.2 Ownership

3.2.1 The complaint is owned by the G4S Sub-Contractor’s Operations Manager but may be handled either by the Personal Advisor or the Operations Manager, depending on the nature of the actual complaint.

3.3 Process for complaint directly from Complainant

3.3.1 Personal Advisor/Operations Manager logs complaint in the G4S Sub-Contractors complaints log and ensures a complaints form is completed

3.3.2 Personal Advisor/Operations Manager acknowledges complaint receipt to the Complainant within three (3) working days in appropriate format. This will include details of how the G4S Sub-Contractor will investigate the complaint (Plan of Response). This needs to be signed off by the G4S Sub-Contractors Operations Manager.

3.3.3 The resolution of the complaint should be achieved within seven (7) working days of complaint receipt. In the event of extended turnaround the Personal Advisor/Operations Manager will update the Complainant on a weekly basis in an appropriate format.

3.3.4 If appropriate, the Plan of Response is reviewed weekly at the G4S Sub-Contractor’s Review Meetings and G4S Management Meetings until complaint is resolved.

3.4 Resolution

3.4.1 If the G4S Sub-Contractor has completed the actions contained in the Plan of Response and the Complainant is satisfied with the outcome of the complaint then it is closed.

3.4.2 The Personal Advisor/Operations Manager logs the resolution in the Subcontractors complaints log.

3.5 Escalation

3.5.1 If the G4S Sub-Contractor has completed the actions contained in the Plan of Response and the Complainant is not satisfied with the outcome then it is escalated to the G4S Regional Team.

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4 Action to be taken upon receipt of a Complaint via the G4S Regional Team

4.1 Method

4.1.1 Complaint delivered verbally, in-writing, via email or over the telephone. Complaint will either be an escalation from the G4S Sub-Contractor or a complaint delivered directly from a Complainant.

4.2 Ownership

4.2.1 The complaint is owned by the Regional Team’s Contract Director and will be handled by the Regional Complaints Point of Contact (POC).

4.3 Process for complaint directly from Complainant (G4S Regional Team will receive a number of complaints directly from Complainant via the complaints email address inbox)

4.3.1 The Regional Complaints POC ensures that emailed complaints have sufficient personal information, provider information and detail for the complaint to be successfully investigated. If not, further information has to be requested from the Complainant.

4.3.2 The Regional Complaints POC reviews the complaint to establish if the complaint has already been investigated by the G4S Sub-Contractor. If not, and if appropriate to do so, the complaint is de-escalated to the G4S Sub-Contractor and the G4S Subcontractor Operations Manager notified of the complaint. G4S Regional Complaints POC to notify the Complainant that the complaint has been de-escalated to the G4S Sub-Contractor, with details of the time frame for response and escalation process should the complainant not be satisfied with the response.

4.3.3 If complaint is not de-escalated, Regional Complaints POC logs the reason for this, and follows process as per escalated complaint.

4.3.4 The Regional Complaints POC acknowledges receipt of complaint to Complainant within three (3) working days in appropriate format. This will include details of how G4S will investigate the complaint (Plan of Response). This needs to be signed off by the Contract Director.

4.3.5 The resolution of the complaint should be achieved within 7 working days of complaint receipt. In the event of extended turnaround the Regional Complaints POC will update the Complainant on a weekly basis in an appropriate format.

4.3.6 If appropriate, the Plan of Response is reviewed weekly at G4S Sub-Contractor’s Review Meetings and G4S Management Meetings until complaint is resolved.

4.4 Process for escalated complaint received from the G4S Subcontractor

4.4.1 The Regional Complaints POC reviews the Complaint Form(s), Plan(s) of Response and other documentation from the provider if applicable or available.

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4.4.2 The Regional Complaints POC acknowledges escalated complaint within 3 working days in appropriate format. This will include details of how G4S will investigate the complaint (Plan of Response). This needs to be signed off by the Contract Director.

4.4.3 The resolution of the complaint should be achieved within 7 working days of complaint receipt. In the event of extended turnaround the Regional Complaints POC will update the Complainant on a weekly basis in an appropriate format.

4.4.5 If appropriate, the Plan of Response is reviewed weekly at G4S Sub-Contractor’s Review Meetings and G4S Regional Management Meetings until the complaint is resolved.

4.5 Resolution

4.5.1 If the Regional Complaints POC has completed the actions contained in the Plan of Response and the Complainant is satisfied with the outcome of the complaint then it becomes closed.

4.6 Escalation

4.6.1 If G4S’s Regional Team has completed the actions contained in the Plan of Response and the Complainant is not satisfied with the outcome then it becomes escalated to the G4S Central Team.

4.6.2 Alternatively at this stage, if appropriate, G4S provides a final, ‘deadlock’ offer letter in accordance with Annex 1 “Standard Wording for your Final Response to the Participant” of the DWP Contractor Guidance. If this is not accepted by the Complainant then the Complainant will be referred to the Independent Case Examiner for an independent review of the case. The complainant has six months from the date of the deadlock letter to escalate their complaint to ICE.

5. Action to be taken upon receipt of a Complaint via the G4S Central Team

5.1 Method

5.1.1 Complaint delivered in-writing or via email. Complaint will either be an escalation from the G4S Regional Team or a complaint directly from a Complainant.

5.2 Ownership

5.2.1 Complaint owned by the Central Team’s Managing Director but will be handled by the Head of Quality and Compliance.

5.3 Process for complaint directly from Complainant (the G4S Central Team may receive a number of complaints directly from Complainants via the personal email addresses of the Head of Quality and Compliance or Managing Director)

5.3.1 In this scenario the complaint will be de-escalated to the G4S Regional Team who will pick up the complaint via the Head of Quality and Compliance. The

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complaint will only come in written formats so the complaint will go to stage 4.3.1 for the Regional Complaints POC to deal with it.

5.4 Process for escalated complaint received from the G4S Sub-Contractor or Regional Contract Director

5.4.1 The Head of Quality and Compliance acknowledges the escalated complaint to the Complainant within five (5) working days in an appropriate format, with clear actions to be taken, by whom and by when and this is executed as soon as is practicable. This needs to be signed off by the Managing Director.

5.4.2 The Head of Quality and Compliance reviews the Complaint Form(s), Plan(s) of Response and other documentation from the provider if applicable or available.

5.4.5 If appropriate, the Plan of Response is reviewed weekly at G4S Sub-Contractor’s Review Meetings and G4S Regional Management Meetings until the complaint is resolved.

5.4.6 In the event of an extended turnaround time the Head of Quality and Compliance or Managing Director will update the Complainant on a weekly basis through the most appropriate method.

5.5 Resolution

5.5.1 If the Head of Quality and Compliance has completed the actions contained in the Plan of Response and the Complainant is satisfied with the outcome of the complaint then it becomes closed.

5.6 Escalation

5.6.1 G4S provides a final, ‘deadlock’ offer letter in accordance with Annex 1 “Standard Wording for your Final Response to the Participant” of the DWP Contractor Guidance. If this is not accepted by the Complainant then the Complainant will be referred to the Independent Case Examiner for an independent review of the case. The complainant has six months from the date of the deadlock letter to escalate their complaint to ICE

Deadlock does not have to happen at the point of escalation to the Managing Director and can occur prior to this point depending on the circumstances.

5.6.1 Independent Case Examiner (“ICE”)

a. ICE has three stages of complaint examination, which will be applied to any complaints made about G4S and the G4S Subcontractors:- Stage 1 Resolution Stage 2 Settlement Stage 3 Investigation Report

b. Financial Penalty If a complaint is upheld against the G4S Sub-Contractor in the ICE report, £5,000 will be payable from the G4S Sub-Contractor to go towards funding the ICE service for provider complaints in the following year.

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