Business Conduct

The Code of Business Conduct of LoveLove Films LTD (the “Company”) consists of the policies relating to the ethical and legal standards of conduct to be followed by Directors, Employees and Agents (including but not limited to part-time, full-time, seasonal staff, placement students and freelancers) of the Company in the conduct of its business. The Code of Business Conduct applies to all Company Directors, Employees and Agents (including but not limited to part-time, full-time, seasonal staff, placement students and freelancers and all company activities throughout the world, except where specifically indicated. It is the policy of the the Company (LoveLove Films) to comply with applicable law. It is the responsibility of each Director, Employee or Agent (including but not limited to part-time, full-time, seasonal staff, placement students and freelancers) to familiarize himself or herself with the details of the policies of the company that apply to his or her assigned duties.

LoveLove Films’ Employee Code of Conduct

The Board of LoveLove Films has agreed the following Code of Conduct for its staff. This code will be an integral part of the staff handbook that forms part of the terms and conditions of the contract of employment for ALL staff. The Board’s responsibilities as an employer are set out in their own Code of Practice and reflected in the policies it has adopted for staff. Any queries about it should be addressed to the Managing Director.s leo.

It is the utmost importance that LoveLove Films maintains public confidence in its integrity, and that of its staff. Staff should, at all times, act in the public interest, and the interest of LoveLove Films. Staff have a responsibility to act fairly, objectively and in good faith. They should be familiar with the company strategy, its aims and objectives, and the internal management and responsibilities that relate to their work.

Responsibilities and duties will be set out by LoveLove Films prior to employment/placement. Staff are expected to familiarise themselves with the contents of this Code of Conduct and act according to the principles set out in it.

The Managing Director has overall responsibility, working under the Board, for propriety in a broad sense, including conduct and discipline.

Staff should serve LoveLove Films in accordance with the principles set out in the Code and recognising:

• their accountability to the Board

• the respective roles of LoveLove Films, as set out in the management and company statement.

LoveLove Films staff should conduct themselves with integrity, impartiality and honesty. They should not deceive or knowingly mislead the Board or the public.

Staff should abide by the rules with regard to private interest and possible and potential conflict with public duty; the acceptance of gifts, the disclosure of commercial and personal and confidential information. They should not misuse their official position or information in their official duties to further their private interests or those of others. All staff should ensure that any possible conflicts of interest are identified at an early stage and that appropriate action is taken to resolve them.

Staff should not use their official position to receive, agree to accept or attempt to obtain any payment or other consideration for doing, or not doing, anything, or showing favour, or disfavour to any person. They should not receive benefits of any kind from any third party that might reasonably be seen to compromise their personal judgement and integrity.

Staff who deal with the public should do so sympathetically, efficiently, promptly and without bias or maladministration. The public is entitled to expect the highest standards of conduct and service from all LoveLove Films staff.

Staff should try, at all times, to ensure the proper, economic, effective and efficient use of resources.

Staff owe a general duty of confidentiality to their employer under common law. They are therefore required to protect official information held in confidence. Nothing in this Code should be taken to override existing statutory or common law obligations to keep confidential, or to disclose, certain information. Subject to the proviso above, staff should act at all times in accordance with the Code & Practice on Access to Information.

If staff believe that they are being required to act in a way which: • is improper, illegal or unethical • is in breach of constitutional convention or a professional code • may involve possible maladministration, fraud or misuse of public funds • is otherwise inconsistent with this Code They should either raise the matter through the Managing Director who will treat the matter in confidence.

Code of Practice on Harassment and Bullying

1.1 LoveLove Films regards harassment and bullying as unacceptable and is committed to their disciplinary. LoveLove Films believes that all employees have a right to be treated with dignity and respect. Acts of harassment or bullying may be dealt with under LoveLove Films disciplinary procedures, and may be classified as gross misconduct should a case prove to be sufficiently serious.

1.2 The aim of this Code of Practice is to eliminate all forms of offensive behaviour, to raise awareness of the effects of such behaviour on individuals and the working environment and to promote a climate in which employees feel able to raise complaints of harassment or bullying without fear of victimisation.

1.3 It should also be noted that harassment on grounds of gender, race, ethnic origin, nationality, disability, religion, sexual orientation, or age are unlawful: they are contrary to the Sex Discrimination Act (1975), the Race Relations Act (1976), the Race Regulations 2003, the Disability Discrimination Act (1995), the Protection from Harassment Act (1997), the Employment Equality (Religion or Belief) Regulations 2003, the Employment Equality (Sexual Orientation) Regulations 2003 and the Employment Equality (Age) Regulations 2006.

1.4 All employees have a personal and legal responsibility not to behave in a manner that could be offensive to others. Designated staff have a responsibility to investigate any complaints of harassment or bullying by a member of staff, and to ensure that all employees are made aware of this Code of Practice.

1.5 In considering perceptions of harassment and bullying, it is very important to be aware of the potential for cultural differences in respect of behaviours. Individuals will have different thresholds and understandings and these need to be considered by everyone who is involved in trying to resolve a particular issue or complaint.

1.6 Intention or lack of intention is clearly important but cannot in themselves be regarded as “evidence” of the reality of harassment or bullying, since the lack of intention may have little bearing on how an act or statement is perceived and experienced.

1.7 In considering complaints under this policy, there is a need to take account of all the circumstances, in particular the perception of the complainant, in deciding the reasonableness of the complaint.

1.8 Given these sensitivities and the scope for subjectivity in perception and understanding, it is important to ensure that an individual accused of harassment or bullying is able to respond fully and explain his/her position before conclusions of any kind are reached.

1.9 The aim of this Code of Practice is to stop unwanted or inappropriate behaviour and find ways in which parties can move forward positively through the establishment of a basis for acceptable working relationships. However, if the behaviour of those complained against is illegal or constitutes a disciplinary offence, then action will be taken through the appropriate procedures.

2.1 Harassment, in general terms, is unwanted conduct that has the purpose or effect of either violating another person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that person in the workplace. It will be related to one of the following: gender, race, ethnic origin, nationality, disability, religion, sexual orientation, or age, and may be persistent or an isolated incident. Harassment may occur in a face-to-face setting, by telephone, in written or electronic communications. The key is that the actions or comments are viewed as demeaning and unacceptable by the recipient and it is important to take account of his/her perception (see 1.5 – 1.7 above).

2.2 Bullying may be characterised as offensive, intimidating, malicious or insulting behaviour, an abuse or misuse of power through means intended to undermine, humiliate, denigrate or injure the recipient.

2.3 Bullying or harassment may be by an individual against an individual (perhaps by someone in a position of authority such as a manager or supervisor) or involve groups of people. It may be obvious or it may be insidious. Whatever form it takes, it is unwarranted and unwelcome to the individual.

2.4 Discrimination is defined as less favourable treatment of an individual or individuals on the basis of gender, race, colour or ethnic or national origin, religion, disability, sexual orientation, social class, age (subject to the usual conventions on retirement), marital status or family responsibilities, or as a result of any conditions or requirements that do not accord with the principles of fairness and natural justice. It can take a variety of forms and may include the following:

2.4.1 direct discrimination, for example, refusing to admit as staff, employ or promote individuals because they are from a minority ethnic group, female, disabled or because of their sexual orientation;

2.4.2 indirect discrimination, for example, setting age qualifications which discriminate against women who have had periods away from work because of family responsibilities.

2.5 The following are some examples of behaviour covered by this Code of Practice. Behaviour can be verbal, non-verbal or physical and examples include:

2.5.1 Unwanted physical contact including unnecessary touching or brushing against another employee’s/student’s body, assault, coercing sexual intercourse, physical threats, insulting or abusive behaviour or gestures.

2.5.2 Unwelcome advances, propositions or remarks, innuendoes, lewd comments or abusive language

2.5.3 Non-verbal Conduct – Making abusive or offensive gestures; displaying of offensive written or visual material2; other unacceptable non-verbal conduct which denigrates a person for whatever reason.

2.5.4Spreading malicious rumours, or insulting someone by word or behaviour.

2.5.5 Ridiculing or demeaning someone – picking on them or setting them up to fail

2.5.6 Exclusion or victimisation

2.5.7 Overbearing supervision or other misuse of power or position

2.5.8 Unwelcome sexual advances – touching, standing too close, the display of offensive materials

2.5.9 Making threats or comments about job security without foundation

2.5.10 Deliberately undermining a competent worker by overloading and constant criticism

Positive, clear management action which relates to conduct or performance or legitimate operational needs taken in a fair and consistent way in line with LoveLove Films’ policies does not constitute bullying or harassment. The term “bullying” describes unfair or prejudicial and unjustified behaviour, decisions or assessments.

4.1 LoveLove Films is committed to investigating allegations fully, fairly, quickly and confidentially. On a practical level, however, it is usually difficult to sort out a problem without some communication with the alleged “harasser”, named witnesses and, in some cases, with the appropriate senior staff/authority.

4.2 Confidentiality is important to all parties affected, particularly in the early stages when an individual feels concerned about the behaviour of another and wishes to seek advice and explore the seriousness of the situation. However, as soon as any attempt is made to deal with the situation in a way that directly involves the individual who is accused, that individual must be informed of the nature of the complaint. Thereafter, there should be an attempt, as far as possible, to maintain confidentiality in respect of all parties while seeking a solution.

This procedure aims to promote fairness and consistency in dealing with reasonable complaints made in good faith. LoveLove Films, however, have a duty to protect its employees from frivolous or malicious complaints or those made in bad faith and appropriate disciplinary action may be taken when it can be demonstrated that a complaint is made on such a basis. Some complaints may prove impossible to uphold; for example if the concern turns out to be due to a misunderstanding or is not capable of being sufficiently substantiated. Where this is the case, and where the complainant is not acting mischievously or maliciously, this will not lead to disciplinary action being taken against the complainant. to maintain confidentiality in respect of all parties while seeking a solution.

LoveLove Films’ approach to complaints is to attempt to resolve them as quickly and informally as possible and at the level at which they occur.

After Leaving Employment

Staff should continue to observe their duty of confidentiality after they have left LoveLove Films’ employment. Staff should be aware of and abide by any rules on the acceptance of business appointments after resignation.

Terms and Conditions of Service

This Code will be part of LoveLove Films’ Terms and Conditions of Service and Employment and is applicable to all staff. Staff who breach the Code may be subject to disciplinary action.

Smoking Policy

Smoking policy for LoveLove Films Effective from 04/08/2014

INTRODUCTION

Second hand smoke is a known health hazard. In 2004, the Government’s Scientific Committee on Tobacco and Health reported that the increased risk to non-smokers of lung cancer from exposure to second hand smoke was 24% and the increased risk of heart disease 25%.

In provisions made under the Health Act 2006, all enclosed and substantially enclosed workplaces and public places will be legally required to be smoke free.

The following policy has been adopted by LoveLove Films to take all possible steps to protect employees from second hand smoke exposure and to comply with legislative requirements.

1. THE POLICY

. 1.1 From 04/08/2014 smoking is prohibited in LoveLove Films’ non-designated smoking premises’. Smoking is also prohibited in company vehicles used by more than one person, and in private vehicles if a passenger is carried. This applies to employees whether employed directly by LoveLove Films, through an agency, by a contractor or other organisation, and visitors. Designated area for smoking is outside by the bench. All cigarettes MUST be disposed of correctly and safely in the fire bucket provided.

. 1.2 Employees who wish to smoke may do so in their own time during lunch?breaks and in one smoking break in the afternoon of no more than ten minutes. Employees will not be permitted to smoke whilst carrying out their duties and responsibilities for LoveLove Films.

. 1.3 The sale of tobacco will be prohibited in all LoveLove Films’ premises.

2. THE POLICY FOR THIRD PARTY PREMISES

2.1 Employees required to visit other premises not covered by smoke free legislation as part of their duties (ie, domestic premises) should advise the visitee when arranging a visit of LoveLove Films’ smoking policy. Although LoveLove Films has a duty of care to protect its employees it cannot control the smoking policy on these premises. Employees should agree that the visitee arrange for a non-smoking area to be provided for the duration of the visit. Where this is not possible, employees should ask the visitee to refrain from smoking inside the premises or in the meeting area for one hour before the visit and that the visitee not smoke during the duration of the visit.

2.2 In circumstances where it is not possible to arrange a visit beforehand, employees should seek advice from their line manager, who should take all reasonable steps to protect them from exposure to second hand smoke.

3. IMPLEMENTATION AND ENFORCEMENT OF THE POLICY

. 3.1 Managers will be responsible for the promotion and maintenance of the policy by their staff. Managers will receive training and guidance regarding their responsibilities in relation to the policy and enforcement of it.

. 3.2 Employees should inform the appropriate manager of anyone who fails to comply with the policy.

. 3.3 Employees not complying with the policy will be referred to their manager for support subject to the usual disciplinary procedure.

. 3.4 Visitors not adhering to the policy will be asked to comply or leave the premises ?or site.

. 3.5 All job applicants will be made aware of the policy via application packs, where a requirement to abide by it will be part of the person specification. Applicants will be reminded of the policy at interview stage.

. 3.6 A copy of the policy will form part of new employees’ induction packs. Training and guidance on enforcing the policy will from part of new managers’ induction process.

4. REVIEW OF THE POLICY

The policy will be reviewed by Georgina Hurcombe six months after the date of implementation and then 12 months from the date of implementation.