Disciplinary Policy and Conduct Standards

` 4.2

08 November 2028

* By selecting that this policy has undergone a full review the approving body are providing confirmation to the Policy Register Holder and King's Executive / Board of Directors that it has been reviewed in its entirety and that the review date can be extended in line with the requirements as set out within the document. Disciplinary Policy and Conduct Standards Page 2 of 39

x:\trustwide policies\archive\

July 2021 Major changes Information regarding fact- finding exercise, removal of informal warning, suspensions reviewed every two weeks, disabled staff can be accompanied by support workers or someone who has knowledge of the disability and its effects, composition of disciplinary hearing panel when the case may result in dismissal, disciplinary sanctions and appeal panel composition for appeals against dismissal John Wall 4.2 May 2025 Periodic review and Minor changes Information on recording meetings and hearings, confidentiality and preparation for meetings and hearings. Change in length of first formal warning.

Seyi Fadiora

All staff through Care Group / Divisional Management teams.

People Directorate

Yes / No

Kingsweb and HR Portal

TABLE OF CONTENTS

The Trust requires high standards of conduct from all employees and is committed to giving employees the opportunity to improve and learn from mistakes where necessary.

The Trust recognises the potential impact that disciplinary procedures can have on the health and well-being of employees and will ensure that the correct support is put in place at an early stage , including reasonable adjustments for employees with disabilities or long-term health conditions.

This policy is intended to ensure that a fair, systematic and uniform ed approach is taken when conduct falls short of the required standard in accordance with the principles of Just Culture. A Just Culture promotes a consistent, fair, and com passionate approach to how employees are treated following patient safety incidents. Rather than assigning blame, it encourages openness and learning by supporting employees to speak up when things go wrong. This fair treatment fosters a culture of transparency and continuous improvement, helping ensure that lessons are learned, and similar mistakes are not repeated.

Managers will always attempt to resolve minor matters of concern through an improvement conversation and by offering any other support required. If informal approaches do not remedy poor conduct or if misconduct is of a more serious nature, the formal stages of the disciplinary procedure will apply.

ANTI-DISCRIMINATION STATEMENT

King's College Hospital NHS Foundation Trust is dedicated to embracing the broad diversity of our staff, patients and communities and stand firmly against all forms of prejudice and discrimination.

Our commitment extends to all protected characteristics under the Equality Act 2010 as well as other vulnerable groups. We expect every employee to respect and uphold this in relation to all our Trust policies, practices, and procedures.

It is against the law to discriminate against anyone because of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality, ethnic or national origin), religion and belief, sex, and sexual orientation.

Discrimination towards our staff or patients, in any form, is strictly prohibited. This includes, but is not limited to, racism, ableism, homophobia, biphobia, transphobia, sexism, ageism, religious discrimination, and any other prejudiced behaviour that undermines the rights, wellbeing and identity of our staff, and patients.

Discrimination can be displayed in various forms including, but not limited to, language, behaviours, unequal treatment, harassment, exclusion, stereotyping, or denying access to opportunities.

We embrace our duty to address discrimination in all its forms, and we pledge to:

- listen to the voices and lived experience of colleagues and patients, and other groups who suffer discrimination or lack of fair representation - commit to working towards removing inequalities within our Trust, including differences in access, experience and outcomes for our diverse patient groups - turn that commitment into positive action and real change Disciplinary Policy and Conduct Standards Page 7 of 39 - use our voice and influence within the wider system to address the wider social determining factors of health - accept our responsibility to listen to, and learn from, the experience of all underrepresented groups - listen with respect and genuine curiosity, acknowledging that continued action and resource is required to bring about the change we need to see - ask all colleagues to work with us to remove unfairnes s and discrimination within our organisation and within our wider communities

2. DEFINITIONS

All terms are explained appropriately within this Policy.

3. PURPOSE AND SCOPE

The Trust's Disciplinary Policy and Conduct Standards aims to help and encourage employees to achieve and maintain the required standards of conduct. This Procedure applies to all employees employed by King 's College Hospital NHS Foundation Trust, including Medical and Dental employees as well as bank and honorary employees.

This Policy does not cover situations in which performance in a job or a programme of training is unsatisfactory because of the knowledge and skills of an employee. These situations are dealt with under the Capability Policy for all non-medical employees and the Maintaining High Professional Standards Policy (MHPS) for Medical and Dental employees.

4. DUTIES (PRINCIPLES)

All employees are required to make themselves aware of and adhere to the King's disciplinary rules and conduct standards, as outlined in Appendix 1. Employees are also required to raise with their manager any concerns they may have about their ability to meet these standards.

Managers have a responsibility for ensuring that employees are aware of the conduct standards. Managers will ensure that any concerns about conduct are brought to the attention of employees at the earliest opportunity and resolved informally where appropriate and if possible.

Managers will ensure that all action taken in line with this policy and procedure is reasonable. Employees will be given the opportunity to know the reasons and the nature of evidence for any potential disciplinary action. Employees will be given the opportunity to be represented at all stages of the procedure. Employees will also have the opportunity to respond fully to allegations before disciplinary action is taken. Managers will ensure that the main points of a formal meeting are summarised in an outcome letter.

Employees have the right to appeal against any formal disciplinary action. With the exception of offences which constitute gross misconduct, employees will not normally be dismissed for a first offence.

If an employee is charged or convicted for a criminal offence, whether committed on or off duty, the Trust will consider whether the offence renders the employee unsuitable for continued employment and may dismiss the employee following a full investigation and properly constituted disciplinary hearing. Disciplinary Policy and Conduct Standards Page 8 of 39

The Trust reserves the right to take action independently of any legal proceedings.

Dismissal due to unprofessional misconduct will be reported to the employee's professional body as appropriate.

5. ROLES AND RESPONSIBILITIES

Line Manager

- It is a fundamental responsibility of managers to take appropriate action to address conduct issues using the Trust Disciplinary Policy and Conduct Standards. This will be taken following a thorough investigation and consideration of the facts and any mitigating circumstances presented by both management and employee. - Managers should always attempt to resolve matters immediately and informally in the first instance in line with the principles of Just Culture, reserving formal action for serious cases and/or where an informal approach has been tried and failed. - Ensure that the appropriate support is put in place for employees subject to disciplinary proceedings. - Adopt a person-centred approach to managing employees. - Consult with the Employee Relations team before taking formal action, including suspension. - Allow accredited trade union representatives to attend formal meetings and disciplinary hearings in accordance with the Trust's Partnership Agreement. - The line manager may be the Commissioning Manager. Where there is a possible conflict of interest, for instance, the line manager is a witness to the incident then they may ask another senior manager to commission the investigation and become Commissioning Manager.

Commissioning Manager

- The Commissioning Manager will be a Senior Manager (generally Band 8A or above). - Is responsible for appointing an Investigating Officer following an initial fact-finding exercise. - Providing the Investigating Officer with clear Terms of Reference to guide the investigation, including listing potential witnesses. - Complete the Pre-Decision Checklist to examine and record consideration of other options, such as informal resolution. - Upon receipt, review the investigation report received from the Investigating Officer and decide whether or not the case should be considered at a formal disciplinary hearing. - Appoint a suitable Chair for the disciplinary hearing. - Should request if employees with disabilities (including long term health conditions) require reasonable changes or accommodations (adjustments) during the process or hearing. Adjustments should be considered individually, based on the employee's specific needs and/or medical or occupational health advice if necessary. - The Commissioning Manager must declare any conflicts of interest in advance.

Investigating Officer

- The Investigating Officer is responsible for undertaking the fact -finding as appointed by the Commissioning Manager. - The Investigating Officer can be a line manager, a senior doctor, a speciali st Employee Relations (ER) Investigator from the ER team, or, if necessary, an external investigator with appropriate expertise. Disciplinary Policy and Conduct Standards Page 9 of 39 - Investigating Officers must have successfully completed the Trust's Conducting Workplace Investigation Training course (sessions can be book via LEAP) or similar training at a different NHS Trust (sessions can be book via LEAP). - Scoping their investigation , collating relevant evidence and identifying the appropriate witnesses guided by the Terms of Reference set by the Commissioning Manager. - The Investigating Officer is responsible for documenting the report and conclusions and presenting them to the Commissioning Manager. - The Investigating Officer should not make recommendations regarding a potential sanction but confine themselves to establishing the facts. - Should the matter be referred to a disciplinary hearing, the Investigating Officer will present the findings. - The Investigating Officer must declare any conflicts of interest before proceeding with the investigation.

The Employee

- Employees have a responsibility to ensure they abide by the Trust standards of conduct and behaviour at all times. - Employees must be available to attend investigation meetings, provide statements/evidence in a timely manner and if applicable suggest relevant witnesses. - To attend the disciplinary hearing, respond to questions and arrange their own representation. - To inform the investigating officer of any reasonable adjustments required, to accommodate disabilities or long -term health conditions, religious or faith needs or caring responsibilities, at the earliest point.

Trade Union Representative

- To accompany the employee at investigation meetings and the disciplinary hearing when required. - Not act in any legal capacity. - May respond to any views expressed at the disciplinary hearing. - May confer with the employee. - Can question the Investigating Officer and/or the presenting manager. - May question witnesses if required. - Not answer questions on the employees' behalf. - Are permitted to address the hearing in line with the employee's wishes. - Cannot prevent management or the Investigating Officer from explaining their case.

ER Team

- Ensure that this policy and process are followed correctly. - Advise employees, managers and trade union representatives on the application of this policy and relevant procedures. - Advise on Employment Law, ACAS code, best practice, relevant policies and procedures and professional Codes of Conduct (where appropriate). - Promote and encourage informal resolution where appropriate. - Accompany, advise and assist managers at formal meetings and hearings. - Ensure that written notes are taken at formal meetings and hearings, including assisting managers with the preparation of outcome letters.

The Investigating Officer should establish a communication plan with an employee who is under formal investigation to ensure regular updates on the investigation's progress.

With consent, employees who are suspended and/or subject to an investigation can be referred to the Occupational Health department by their line manager for support regarding health and wellbeing and advice regarding reasonable adjustments if applicable.

Where necessary, reasonable adjustments should be considered to avoid disadvantaging affected employees and ensure fair treatment throughout the disciplinary process. This includes making reasonable adjustments, in line with the Reasonable Adjustments Policy for employees who have a disability, long-term health condition, neurodivergence, or any other condition that may affect their ability to participate fully in the process. Reasonable adjustments will be considered at all stages of the disciplinary process.

Other reasonable workplace accommodations outside the scope of disability and long -term health conditions may also be considered, such as those based on faith, religion, or belief or caring and/or parental responsibilities to ensure that all employees are treated fairly and equitably during the disciplinary process.

All employees should be made aware of the support available to them , (e.g. Trade Union support, Freedom to Speak Up Guardian, Employee Relations team , Well-being Team and the Employee Assistance Programme), to ensure that they feel safe to speak up throughout the process.

7. INFORMAL PROCEDURE

7.1 Fact-Finding Exercise

The line manager will carry out a fact -finding exercise in line with Just Culture to review the whole event and make a decision regarding next steps. The fact-finding exercise will aim to establish dates and time of the incident, individuals involved in the event and witnesses. The line manager will also gather any other relevant infor mation such as patient's notes, rotas, emails, file notes, local arrangements, etc.

A fact-finding exercise is not part of a formal process and should start with a conversation with the individuals involved in the event. Statements should be obtained including witnesses if appropriate. Managers should consider all the information and any mitigation or contributing factor before deciding on next steps.

7.2 Improvement Conversations

In cases where minor misconduct is established for the first time, the line manager should meet with the employee in private for an improvement conversation to discuss the unsatisfactory conduct at the earliest opportunity. The manager will hear any reasons or mitigation put forward and will advise the employee of the expected standards of conduct and, where appropriate, assistance will be offered to help the employee achieve those standards and the timescale for them to be met. If necessary, further training, counselling, coaching, mentoring, supervised practice, facilitated conversation and mediation will be agreed with the employee, which will be followed up by the line manager. Disciplinary Policy and Conduct Standards Page 11 of 39

The employee will also be informed that if there is a repeated act of minor misconduct, further action will be considered i.e., formal stages under the disciplinary procedure being invoked.

The details of the Improvement Conversation will be confirmed to the employee in writing, and they will have the right to provide their response . Managers should save a copy of the Improvement Conversation on the employee's personal file and a copy sent to the Employee Relations team.

8. FORMAL PROCEDURE

8.1 Formal Investigation

A fact-finding exercise will be carried out before formal disciplinary action is taken. Please refer to section 7.1 for further guidance.

The Commissioning Manager will complete the Pre-Decision Checklist (available via the Employee Relations Team) to examine and record consideration of other options, such as informal resolution.

In the event that the Commissioning Manager considers that a formal investigation is the way forward, the Employee Relations Advisor will take the Pre-Decision Checklist to the Triage panel for discussion. The Triage Panel , chaired by the Head of Employee Relations reviews the reported allegations of misconduct and considers appropriate next steps. If the Triage Panel considers that the case meets the criteria for a formal investigation, the Triage Panel will recommend this course of action. The Oversight Group which is chaired by the Chief People Officer with attendance of an Equality, Diversity and Inclusion representative, Associate Director of People, Head of Employee Relations, and Deputy Chief Nurse will oversee and monitor the formal Disciplinary cases ensuring cases are progressing and resolved timely.

It is anticipated that once a formal investigation begins, it will take no longer than 4 weeks to complete.

Clear terms of reference should be given to the Investigating Officer by the Commissioning Manager, which will outline what allegations are to be investigated and the timeframe to conclude the investigation.

As part of the investigation, it is usually necessary for the Investigating Officer to meet with the employee to establish their version of events. Where this is not possible then the employee under investigation may be permitted to give their explanation by other means, such as providing a written statement.

The employee has the right to be accompanied by an accredited Trade Union representative or a workplace colleague employed by the Trust. In addition, a disabled employee may also be accompanied by a suitably qualified individual such as a support worker or someone with expertise in their disability and its effects, who can advocate on their behalf.

Investigations should be completed within 4 weeks and not delayed without good reason. If an Investigating Officer is unable to obtain relevant information in a reasonable timeframe, consideration may be given to concluding an investigation based on the information available.

The Investigating Officer must be mindful of the need for a fair and balanced investigation and give Disciplinary Policy and Conduct Standards Page 12 of 39 the employee every reasonable opportunity to give their explanation and views. The Investigating Officer should keep the employee informed of the progress of an investigation on a regular basis. It is noted that Trust CCTV and other evidence will be utilised where there is a specific and legitimate aim relating to the disciplinary investigation and allegations.

If an investigation relates to an allegation of fraud, the Trust's local Counter Fraud specialist will be informed and will investigate as required. Investigations conducted by the Counter Fraud Team, Police or other agencies are independent and separate from those carried out under this Procedure. The Trust will only postpone or halt disciplinary investigations because of other investigations if continuing would jeopardise or obstruct the outcome of the external investigation. The decision to proceed should be made in consultation with the relevant agencies but will always be made in the best interests of the Trust.

8.2 Agreed Outcomes Where an employee has admitted and accepted the allegations against them, the manager in consultation with the Employee Relations team may consider whether it is appropriate to conclude the matter without the need for a formal investigation and /or disciplinary hearing by agreeing an outcome with the employee. It is open to either party, without prejudice, to suggest an agreed outcome at any stage of the disciplinary process.

This approach can only be considered where the outcome of any disciplinary process in relation to the alleged conduct will be no more serious than a first or final formal written warning and therefore, it excludes cases where the potential outcome is summary dismissal or dismissal with n otice. The employee should be given up to 7 days to consider whether to accept the agreed outcome. If the employee consents to an agreed outcome, a meeting will be held with the relevant manager supported by a member of the ER team, the employee and their representative. The agreed outcome will be confirmed in writing within 7 days by the manager.

Any disciplinary sanction issued in this way has the same validity as one issued after a disciplinary hearing. However, once the decision has been agreed upon during the meeting with the manager, there is no option for an appeal or raising a grievance against it.

8.3 Criminal Matters (Inside or Outside the Trust)

In cases where criminal activity is suspected, for example theft, assault, etc. consideration needs to be given to informing the Police, Security Team, Counter Fraud Team or Health and Safety Executive in the first instance as well as seeking legal advice in order that a proper investigation can be conducted. The Employee Relations team should be contacted at the earliest opportunity.

Where an employee is arrested, subjected to a criminal investigation, is charged, or has received a caution / sentence for a criminal offence inside or outside of work, it is the employee's responsibility to inform their manager of the circumstances as soon as possible. Failure to do so could result in disciplinary action up to and including dismissal.

Where the misconduct is the subject of a criminal investigation or legal process internally or externally, the Trust has the discretion to proceed with its own internal investigation and disciplinary in accordance with this policy, without awaiting the outcome of any criminal investigation or prosecution. However, consent should be sought from the investigating team and or Police in order Disciplinary Policy and Conduct Standards Page 13 of 39 not to compromise any criminal investigation.

A criminal offence outside employment will not automatically be regarded as a reason for disciplinary action or dismissal. The main consideration will be whether the conviction has clear implications for the performance of the employee 's duties (i.e., imprisonment, driving ban where driving is a requirement of the role, etc ), or is such that it damages the reputation of the Trust. If this is the case, disciplinary action up to and including dismissal may be taken.

If it is decided that the offence could affect the performance of the individual or bring the Trust into disrepute, then a formal investigation may need to commence.

If matters of a potentially criminal nature arise during an investigation the Police, Security Team, Counter Fraud or Health and Safety Executive may be informed. Legal advice should be sought through the Employee Relations Team.

Where someone is unable to attend work due to being detained by the authorities, the Trust may continue with the process in the employee's absence. In this instance, if an employee is unable to attend meetings and /or hearings, then they may send a representative on their behalf and or provide a written statement.

8.4 Conduct issues that occur outside the workplace

Misconduct may sometimes occur outside the workplace, such as during social events, in public places, at home, or on social media. If such misconduct impacts or has the potential to impact colleagues, patients, or the Trust's reputation, this policy and its associated sa nctions will apply . Employees must disclose any arrests, cautions or sanctions to their Line Manager.

9. SUSPENSION/EXCLUSION

Suspension is a last resort and should only be considered in cases of alleged serious misconduct where there is:

EITHER a need to protect patients, employees or the Trust 's business interest pending a full investigation into allegations of gross misconduct.

OR the presence of the employee in the workplace is likely to hinder an investigation

AND there is no workable alternative to suspension.

Suspension will be for the minimum time necessary and will only be used after alternative ways of managing risks have been considered. All su spensions will be reviewed every two weeks by the suspending manager and if applicable an extension or lifting of suspension letter will be sent to the employee.

Suspension is a neutral act and is not a form of disciplinary action . However, any breach of the conditions attached to the suspension may result in disciplinary action.

Before suspending an employee, approval must be sought from the Employee Relations Team and all suspensions must be reported to the Head of Employee Relations. If a decision to suspend is made out of hours, the Head of Employee Relations should be notified at the earliest possible Disciplinary Policy and Conduct Standards Page 14 of 39 opportunity by the relevant Senior Manager on site or on call. Suspension is a last resort and the decision to suspend, following consultation with the Employee Relations Team, should be made by the appropriate senior manager (usually Band 8B or above unless in exceptional circumstances, where explicit delegated authority is given to a more junior manager). Following a suspension, the suspending manager will notify the employee's line manager (if different). In cases involving safeguarding concerns, the Trust's Safeguarding Lead will also be informed. Where the concern involves a child, the responsible safeguarding manager must contact the Local Authority Designated Officer (LADO) within 24 hours of the concern being raised. In certain circumstances, the suspending manager may also notify the Security Team to disable the employee's Trust ID badge access and network login, as appropriate. If a suspension is lifted, the same parties will be notified to ensure access and systems are restored where applicable. If the suspension relates to a lapse in professional registration or right to work status, the Payroll Department will also be informed. Suspension is on full pay meaning the employee will receive the pay they would have earned if they had been at work. However, if the suspension is a result of lapsed professional registration, ineligibility to work due to visa expiry or restrictions, statutory bar (for instance a Trust driver losing their driving license) or an ongoing criminal investigation/criminal charges then the suspension will be unpaid. People on zero hours contracts or registered on the bank will not receive pay during suspension.

During the suspension period, the employee will not be permitted to enter any Trust premises other than:

- For the treatment of themselves or their family, including attending Occupational Health appointments.

- At the request of the Investigating Officer or line manager to attend a meeting.

- To meet with their Trade Union representative by prior agreement.

Should the employee wish to meet with their Trade Union representative then this should be discussed and agreed with their line manager in advance. Whilst on site the employee must not make any attempt to contact their place of work or approach anyone involved, or likely to be involved in the case in accordance with the conditions attached to the suspension.

As a condition of the suspension the employee must not undertake any new or related employment (including agency or bank) elsewhere during their contractual hours . Any change of address or personal circumstances (such as leaving the country) must be notified to their manager. While suspended, the employee must not work through King's Bank Partners.

The employee must be available for meetings related to the investigation during their normal working hours within reason. During suspension pre-booked annual leave will be honoured. If the employee wishes to take annual leave during the suspension period, this must be requested as per the Trust's annual leave procedure.

Disciplinary Policy and Conduct Standards Page 15 of 39 The suspending manager must write to the employee following suspension to state the allegation(s), the reasons for suspension and confirmation of who commissioned the investigation. The letter must include the name of the Investigating Officer that will contact the employee. Management should maintain regular contact with the employee as a supportive measure for the duration of the suspension. The method and frequency of this contact should be tailored to individual needs and should always serve as a supportive measure. It is recommended that contact should be as a minimum held fortnightly.

If a decision is made to lift the suspension and allow the employee to return to work, then this should be confirmed in writing to the employee as soon as possible, noting any specific arrangements in relation to the employee's return to work.

A discussion should take place between the line manager and employee to discuss their return to work, before the letter is sent.

For Medical & Dental employees refer to the Maintaining High Professional Standards (MHPS) policy for Medical and Dental Staff.

10. FORMAL PROCEDURE FOR DISCIPLINARY HEARINGS

Once the matter has been investigated and it has been established that there is a case to answer, a disciplinary hearing will be arranged without unnecessary delay.

Reasonable notice, normally 7 calendar days, must be provided regarding the arrangements for the hearing, including confirmation of who will be present at the hearing. The Chair of the disciplinary hearing will provide the employee in advance with written details of the allegation(s) and any witness statements or supporting documentation that will be referred to at the hearing, and where applicable the investigation report and appendices. The employee must make all reasonable efforts to attend the hearing. If employee attendance is not possible, they may submit a written statement or ask a representative to attend on their behalf.

If the employee has a legitimate reason that prevents them from attending the disciplinary hearing, then they should ask the Chair of the disciplinary hearing via email or letter if they would be prepared to reschedule the hearing. However, the decision on when the hearing should be held rests solely with the Chair. If an employee fails to attend a scheduled hearing without prior notification, the hearing may proceed in the employee's absence and a decision made accordingly.

The employee has the right to be accompanied by an accredited Trade Union representative or a workplace colleague employed by the Trust. In addition, a disabled staff member may also be accompanied by a suitably qualified individual such as a support worker or someone with knowledge of the disability and its effects who can advocate on their behalf. Where action is proposed involving an accredited Trade Union representative, the appropriate full-time officer will be contacted before action is initiated. It is the employee's responsibility to arrange representation.

The representative's role can include addressing the hearing on the employee's behalf, putting forward the employee's case and summing up, responding on behalf of the employee to any views expressed at the meeting and to confer with the employee. Representatives cannot answer questions on the employee's behalf.

Cases that may result in dismissal will be heard by a Chair who will be banded at band 8 CC8C or above supported by an additional panel member who can be an independent/specialist adviser. The Disciplinary Policy and Conduct Standards Page 16 of 39 panel will be advised by a People Directorate representative.

Panel members will have no previous involvement in the case or any conflict of interest that could affect their impartiality. Panel members will be diverse in representation, taking into account factors such as ethnic background, gender and disability. Panel members will be selected to achieve this diversity, and where necessary additional panel members will be recruited to ensure there is appropriate representation.

The duration of the hearing will vary depending on the case however, a minimum of 3 hours should be set aside. At the start of the hearing the Chair will outline the nature of the allegations and explain the format of the proceedings. The employee will be given full opportunity to respond to the allegations. While the employee is expected to answer questions directly their representative has the right to present the employee's case and ask questions on their behalf. When considering any sanction, the Chair will take account of the employee's previous record and other relevant factors.

Witnesses will be called in person only if they have a significant contribution to make to the case. It is the decision of the Chair if witnesses are required. Where it is not possible for a significant witness to be present on the day of the meeting, then the Chair, the People Directorate support and the Trade Union representative may arrange to meet with the individual in advance, and a note of that preliminary meeting will be included in the case papers.

The outcome of the hearing will be confirmed in writing within 7 calendar days. Any delays to this timeframe should be communicated to the employee and their representative at the earliest opportunity, detailing the reasons for the delay and an expected time frame.

If a sanction is imposed by the panel the outcome letter will specifically detail which allegations are upheld and if applicable not upheld. Any expected improvement and recommendations will be detailed including the time frame. Employees will be given 14 days to appeal the outcome of the disciplinary hearing.

If the employee is professionally registered, the Chair of the Hearing will consider whether the circumstances warrant a referral to the employee's professional body, if so referrals for nurses will be discussed with the Chief Nurse. and the Chief Medical Officer for doctors. If a referral is deemed necessary, the employee must be informed accordingly.

10.1 Counter-Allegations during a Disciplinary Process

If an employee makes a counter-allegation that is relevant to a disciplinary proceeding, these allegations may be considered as part of the disciplinary process and not separately under another procedure. If appropriate, it may be necessary to consider the counter allegations as part of mitigation submissions during the disciplinary hearing.

11. FORMAL DISCIPLINARY SANCTIONS

The severity of the misconduct will determine the appropriate level of disciplinary action. Formal disciplinary sanctions may be imposed at any stage, depending on the circumstances.

Previous formal disciplinary warnings may be considered as part of the employee's overall disciplinary record. Any warnings that are "live" at the time of the incident may be considered when determining the appropriate sanction.

If an employee fails to meet the required standards following informal action or if the misconduct is of a more serious nature to warrant moving straight to the formal stages, a Formal First Written Warning may be issued. Formal First Written Warnings will be confirmed in writing and will remain active for a period of twelve months, after which it will lapse.

Stage 2 -Formal Final Written Warning

If an employee fails to meet the required standards or if the misconduct is serious but does not constitute gross misconduct, a Formal Final Written Warning may be issued. Formal Final Written Warnings will be confirmed in writing and will remain active for a period of twelve months, after which it will lapse.

Note: In exceptional circumstances , the duration of a Formal Final Written Warnings may be extended up to twenty-four months where the warning is an alternative to dismissal.

Their line manager should notify Payroll.

Stage 3 - Dismissal

If the conduct or performance remains unsatisfactory or if the incident constitutes gross misconduct, the outcome will normally be dismissal. The Chair of the disciplinary hearing (who will be a Band 8C or above) has the authority to make this decision . In cases not involving gross misconduct, d ismissal will be with pay in lieu of notice. However, in cases of gross misconduct summary dismissal without notice will apply.

Alternative and / or additional action

The Chair also has the discretion to impose alternative sanctions instead of, or in addition to a formal warning or dismissal. This may include for example, demotion or redeployment.

12. RECORDINGS When conducting investigation meetings or disciplinary hearings, explicit consent must be obtained from all participants before any recording takes place. Recording is only permitted using Microsoft Teams, and no personal recording devices may be used under any circumstances. Meeting notes are typically taken by the Investigating Officer (at investigation meetings) or a representative from the People Directorate (at hearings) . These notes are not verbatim but will accurately capture the key points and discussions during the meeting. Where a meeting is recorded, a transcript will be provided to the relevant parties. Covert recording is strictly prohibited and may itself be treated as a disciplinary matter. 13. CONFIDENTIALITY Employees involved in disciplinary cases must always maintain confidentiality and should only discuss the matter with an appropriate manager, their accredited trade union representative, or a Disciplinary Policy and Conduct Standards Page 18 of 39 member of the People Directorate team. All documentation related to the disciplinary process should be treated as confidential and only shared with individuals directly involved in the investigation. All meetings and hearings should be conducted in a private setting, free from interruptions. This applies equally to remote meetings, where participants must also ensure confidentiality and privacy are upheld. 14. PREPARATION FOR MEETINGS AND HEARINGS

If an employee requires time off work to prepare for a formal disciplinary case with their accredited Trade Union representative, they should submit a request to their line manager. Such requests will not be unreasonably refused; however, consideration wil l be given to service needs when granting time off.

15. APPEALS

Employees have the right to appeal against any formal disciplinary action (except an agreed outcome). Appeals must be directed to a higher level of management who was not previously involved in the original disciplinary decision. Appeal hearings should be scheduled within 4 weeks and will be heard under the Appeals Policy.

Appeals will be heard by a panel comprising of two senior managers. who are appropriately. The panel members will not have had any prior involvement in the case and must not have any conflict of interest that could influence their impartiality. For cases involving dismissals, the Chair of the Appeal hearing will be a Band 8D or above who holds a more senior position than the Chair of the Disciplinary hearing. A different People Directorate representative will support the panel. The panel will be diverse in representation.

Employees wishing to appeal must submit their appeal in writing or by email to the line manager of the Chair of the disciplinary hearing, copying in Employee Relations. The outcome letter will specify who to address the appeal submission to. All appeals must be submitted within 14 days of the date of the outcome letter and must clearly state the grounds for appeal.

The appeal hearing does not revisit the entire original hearing but focuses specifically on the issues raised in the grounds of appeal. In accordance with the Trust's Appeals Policy, an appeal may be submitted on the following grounds:

- A procedural error - The decision was unfair and unreasonable - That further new material information has come to light which, had it been known by the panel at the time of the hearing, may have affected the panel's decision. This must be information that was unavailable at the original hearing or meeting and is pertinent to the case.

16. IMPLEMENTATION AND TRAINING

The Trust will ensure that managers with responsibility for disciplining employees are appropriately trained. King's provides the following training provisions:

- New employees are made aware of the disciplinary procedure and rules (Appendix 1). - Disciplinary Training is available in the management of misconduct and the application of this Disciplinary Policy and Conduct Standards Page 19 of 39 procedure for new and existing managers, with a particular focus on the need for informal resolution where appropriate. This training is available to book onto via LEAP (Learning Management System) Effective People Management - Conducting Workplace Investigations Training is available to support staff who carry out investigation and outline the process to do so. This training is available to book onto via LEAP (Learning Management System) Conducting Workplace Investigations - Training on Equality and Diversity and its relevance to disciplinary matters.

17. MONITORING COMPLIANCE

Managers will ensure that the disciplinary procedure is applied fairly and consistently in line with the Trust's Equal Opportunities Policy. The application of the formal procedure by ethnicity, gender, disability, sexual orientation and age is monitored by the People Directorate. Factors such as directorate, occupational group and length of service are also monitored. Reports on the application of the procedure are discussed at the Partnership Committee, management team meetings and at meetings within the Trust's Equality and Diversity governance structure and action taken accordingly.

18. ASSOCIATED DOCUMENTS

- Appeals Policy - Capability Policy - Early Resolution Policy - Equal Opportunities Policy - Induction Policy - Professional Registration Policy and Guidance - Sickness Absence Policy - Suspension Policy - Reasonable Adjustments Policy - The King's Values and My Promise

Appendix 1- Trust Values

Making King's a positive and caring place according to our Trust values is the responsibility of all of us.

KIND

I will: - care for people's dignity and privacy - treat everyone as a valued individual - be considerate - take the time to understand others' concerns, with empathy, putting myself in their shoes - bring an optimistic, 'can do' attitude - value others - say thanks and smile if appropriate

I won't: - be rude, uncivil, abrupt or aggressive - undermine others, bully, belittle or shout - fail to consider other people's perspectives - be dismissive of others' feelings, stories or journeys - be problem-focused - moan without acting - ignore others' good work or 'take the credit'

RESPECTFUL

I will: - ensure equity for everyone - embrace diversity and difference - be impartial and open-minded - be approachable, welcoming, connecting and encouraging - involve people in trusted relationships - speak up when I need to, and be open to receiving feedback as a chance to learn

I won't: - judge, discriminate, make assumptions or be intolerant of others' views, choices or differences - exclude, isolate or blame people - 'go it alone' or work in a silo - gossip - withhold information - criticise mistakes - stay silent when I need to speak up - be closed to feedback

TEAM

I will: - be attentive, noticing when others need help and be willing to offer it - be friendly and helpful - communicate openly, explain clearly, share information regularly and listen with curiosity - be responsible for my attitude: calm, polite, patient, reassuring and look to learn and improve

I won't: - avoid helping if someone needs it - make people feel 'a burden' - take a 'not my job' attitude Disciplinary Policy and Conduct Standards Page 21 of 39 - dictate, interrupt or lecture people - argue rather than discuss - use jargon - talk over people - accept low standards - resist change, learning or improvement - pass my stress on to others

The following gives an indication (but not an exhaustive list) of the circumstances that could lead to disciplinary action. In addition, many departments have specific rules relating to the activities of that department, which failing to adhere to may also result in disciplinary action being taken. While a first breach of the following general standards of performance and conduct would not normally result in dismissal, continued breaches, after warnings and opportunities to improve, could cumulatively do so.

1. Employees are expected to combine prompt and efficient service with a concern and respect for the feelings of others, including patients, visitors and colleagues, whatever their background. As a minimum all staff are expected to:

- Treat everyone with respect and dignity - Maintain privacy and confidentiality at all times - Introduce themselves to staff and other visitors by name and role - Avoid using first names of patients and other visitors without permission - Wear an identification badge that is visible to the public - Greet everyone in a friendly manner - Smile and speak clearly - Avoid using offensive or threatening language - Help members of the public who appear to be lost - Offer to assist an enquiry in a polite and helpful manner - Apologise and explain if someone has been kept waiting - Use English as their first language and only use other languages unless explicitly asked. Employees should not converse / communicate with each other in languages other than English unless they are on a designated break and are not in an area with patients

2. Employees are expected to attend for duty for the hours laid down in their Contracts of Employment or as agreed with management. The distance of an employee's home from work or any difficulty of access / travel problems cannot be accepted as a reason for irregularity of attendance.

3. Employees are expected to present themselves for work unless they have prior permission to be absent. In cases of sickness or sudden domestic emergency, the responsibility lies with the employee to inform their manager, as soon as possible and no later than the start of their shift, in accordance with departmental notification rules.

4. Employees undertaking other employment outside their contractual hours (including stand-by duty and secondary employment) must ensure that this in no way hinders or conflicts with the interests of their employment with the Trust or their duty to abide by their professional code of conduct (as appropriate) or has any adverse effect upon their performance of their duties. Employees should inform their managers of employment outside working hours in order to prevent a possible conflict of interest.

5. During sickness absence, employees are expected to keep management informed of their progress and likely date of returning to work. Sickness certificates must be submitted in line with requirements laid out in the Trust's Sickness Procedure.

6. Employees should carry out the reasonable instructions of their managers.

7. Employees are expected to comply with all health and safety requirements.

8. Employees are expected to keep the hospital clean and tidy and treat the facilities with respect.

9. Employees should at all times undertake their work in accordance with Trust and departmental policies and procedures and, where appropriate, their professional codes of conduct.

10. Employees are under an obligation to inform their managers of any police arrest, investigation, charge or conviction, relating to acts committed on or off duty, at the earliest possible opportunity. Where appropriate staff should also report convictions to their professional body.

11. Employees are banned from smoking anywhere on Trust property and on any other NHS facility. Employees are prohibited from smoking anywhere if they are in uniform.

2. Examples of Misconduct

Examples of the types of misconduct which may be considered as minor, serious and gross misconduct are detailed below. This list is neither exhaustive nor prescriptive and therefore does not include all types of misconduct and should only be used as a guide. It will be for the Chair of the disciplinary hearing to determine the findings based on the evidence. In all cases, the severity of the breach of conduct will determine the stage at which the disciplinary procedure is entered, and the level of disciplinary action taken.

Examples of Minor Misconduct

- Failure to comply with a reasonable order - Late attendance and/or inappropriate timekeeping - Failure to provide a doctor's sick certificate, which may be an electronic certificate. - Examples set out above in Section 1

Examples of Serious Misconduct

- Adversarial relationships with colleague that prevents the employee or their colleague(s) from carrying out their duties satisfactorily - Breach of confidentiality - Ill treatment/abuse of colleague/patients - Inappropriate use of the Trust internet, email or social networking sites - Inappropriate or continuous use of personal mobile phone within the workplace - Unauthorised and/or inappropriate use of computers and/or software, including the use of personal software on the Trust's systems. When an employee recklessly or without reasonable cause acts in a manner that damages or is likely to damage the reputation of the Trust - Use of foul language in the workplace - Failure to comply with health and safety requirement - Failure to comply with mandatory Trust procedures - Failure of managers and/or individuals to ensure statutory and mandatory training is completed unless there are exceptional circumstances - Making malicious, vindictive or deliberately untrue statements against colleagues, another employee or patients - Absence without proper cause and unauthorised absence including leaving work early or without permission - Loss, damage to or misuse of Trust equipment, facilities and/or property, assets or funds through negligence or carelessness - Failure to comply with Trust information governance protocols, leading to the risk of a breach of data security

Examples of Gross Misconduct

The following offences are among those regarded as serious enough to warrant summary dismissal, without any prior warnings, as constituting gross misconduct. (The list is not exhaustive). Summary dismissal will result in no pay in lieu of notice,

- Theft - any instances of theft or attempted theft from the Trust or from patients, visitors or staff. This includes unauthorised personal use of Trust property on the premises.

- Fraud - this includes any deliberate falsification of records or documents, such as the misrepresentation of entitlement to expenses or allowances, the falsification of time sheets. It also includes false declarations made during the recruitment process.

- Corruption - the receipt of money, goods, favours or excessive hospitality in respect of services rendered (for example, from contractors in anticipation or recognition of receiving orders for goods), or failure to follow the Conflicts of Interest Policy. .. - Assault - any assault (verbal or physical) upon a patient, member of the public or fellow employee, including cases of serious harassment and bullying.

Discrimination

- Negligence - any action or failure to act which could result in serious loss, damage or injury. Includes failure to give appropriate care and protection to patients.

- Reckless Conduct - an act of recklessness or incompetence sufficiently severe to break down trust and confidence in the employee's ability to undertake their job.

- Deliberate damage - to health service property or equipment, or the property of patients, visitors or staff.

- Being unfit for duty - through the effects of drink or drugs subject to the provisions of the Trust Policy on the Use of Drugs and Alcohol, or by being asleep on duty (unless authorised to be so e.g. on standby duty).

- Wilful failure or flagrant refusal to carry out reasonable instructions or rules - where the employee fails to give a satisfactory reason for such a refusal.

- Abuse or misuse of health service property - including the unauthorised use/theft or incorrect disposal of drugs or anaesthetic gases.

- Working in a role without the legal authority to do so - where an employee through their own action or inaction loses their statutory right to perform the duties for which they are employed. For example, loss of professional registration, no right to work in UK / visa restrictions, loss of statutory required qualifications such as a driving license (for a driver) etc.

Examples of Gross Misconduct continued

- Breach of confidentiality - disclosure of confidential patient or employee information to unauthorised persons, including accessing patient or colleagues' records on Trust systems (such as EPIC) without a legitimate reason, such as providing direct care.

- Serious infringement of health and safety rules

- Failure to observe corporate compliance - this includes failing to follow standing orders and Standing Financial Instructions, or failing to act impartially or to declare an interest in a contract or business in which the Trust is engaged or considering. This relates to situations which may be influenced by social or business relationships, where the employee's public or private interests may be furthered or the Trust's decisions, policies or business interests may be affected.

- Failure to report serious concerns - e.g., concerns about the mistreatment or abuse of patients or employees.

- Bringing King's into disrepute - this rule may be breached when an employee intentionally or recklessly acts in a manner which damages or is likely to damage the reputation of the Trust, for example through unauthorised disclosure to third parties (subject to the provisions of the Trust Policy on Raising Concerns) or through conduct incompatible with role or profession and / or is charged / convicted of a criminal offence. Employees should be extremely careful in their use of social media and ensure that their opinions on social media do not link to their position at King's and they must not allow their opinions to bring the organization into disrepute.

- Scientific Misconduct - fabrication, falsification, plagiarism or deception in proposing, carrying out or reporting results of research or deliberate, dangerous or negligent deviations from accepted practices in carrying out research.

- Breach of Trust - this rule may be breached when an employee acts in such a way to fundamentally damage the relationship of trust and confidence between the employee and King's.

Disciplinary Policy and Conduct Standards Date of Assessment June 2025 What are the aims of this project, policy, function, and or service?

All employees are expected to uphold high standards of conduct to ensure patient safety and promote a fair, supportive workplace. This policy outlines clear procedures for addressing allegations of misconduct and ensures a consistent approach is applied across the Trust. It's primary aim is to support all employees in meeting the expected standards of behaviour, while ensuring that no individual or group is treated unfairly based on any protected characteristic. Who could be affected by this proposal? (e.g. applicants, employees, customers, service users, members of the public)

This policy is applicable to all employ ees at the Trust whose conduct may be questioned and may be impacted through an investigation, disciplinary hear and a sanction.

Patients and members of the public may be directly or indirectly impacted. This policy helps maintain professional standards, which in turn safeguards patient care and trust in the healthcare system.

Which policies are related to or referred to as part of this assessment?

Appeals Policy Suspension Policy Equal Opportunities Policy Early Resolution Policy

How will the impact on people be assessed? (e.g. consultations forums, meetings, data collection) Data c aptured by the ER Tracker should highlight whether the policy is contributing to fairer outcomes across all staff groups. A key indicator of improvement would be a reduction in the disproportionate number of ethnic minorities' staff entering the formal disciplinary process compared to their white counterparts. Additionally, there should be a decrease in the severity of sanctions disproportionately affecting any particular group. Feedback should reflect a consistent perception of fairness in how disciplinary procedures are applied, with no single group reporting significantly different experiences or outcomes.

Please include available Equality Data relating to the use or implementation of this policy, project, function or service? (e.g. Care Group breakdown, WRES, WDES, Sexual Orientation monitoring standard, Patient Feedback, Workforce data etc.) Disciplinary Policy and Conduct Standards Page 28 of 39

Trust data shows that ethnic minority staff are both overrepresented in disciplinary cases and in disciplinary outcomes. The data suggests a potential disparity that may warrant further investigation into bias and inconsistent application of the policy. Below is the current Trust data breakdown by demographics:

Which stakeholder consultations have been included in the development or implementation of this policy, project, function or service?

Employee Relations Team People Business Partners Equality, Diversity and Inclusion Team Workforce Information data

Disciplinary Policy and Conduct Standards Page 29 of 39 What are the potential impact/s of implementing this policy, project, function or service on people who share protected characteristics as listed below?

Protected Characteristic: Neutral

Age (People of all ages)

x Trust data shows the majority of staff are aged between 27 and 40. This policy applies equally to all age groups. All employees should be managed fairly and consistently under this policy. Currently, no age -specific data is recorded on the ER Tracker, so monitoring for age -related disproportionality is limited. This will be identified in the ER action plan to be incorporated on the ER tracker. Age would need to be included in data recording to allow analysis to identify any future trends. Disciplinary Policy and Conduct Standards Page 30 of 39 Disability (Mental, Physical, and Carers of Disabled people)

x This policy promotes fairness for disabled staff, ensuring reasonable adjustments are made where appropriate. Referral to Occupational Health is encouraged to support participation in investigations and hearings.

The Commissioning Manager or Chair of Hearing Panel is expected to ask the employee if they require any reasonable accommodations or changes ( adjustments) to support them during all phases of the disciplinary process; to reduce the opportunity or possibility of disciplinary discrimination.

Managers are to consider whether a disability may have influenced alleged misconduct.

Workforce Composition for disability: - No: 87.35% - Yes: 3.49% - Not declared: 9.16%

Based on the data for the number of disciplinary cases in a 12 month period, April 2024 - March 2025, There were 73 disciplinary cases in total. Disability was recorded as:

- No: 67 (91.78%) - Yes: 3 (4.11%) - Not declared: 3 (4.11%) Disabled staff (3%) make up a small portion of the workforce but account for 4.11% of disciplinary cases - a slight overrepresentation. Non-disabled staff (majority of the workforce) appear proportionately represented , though slightly over in disciplinary cases. Staff can access support via King's Able Network King's Able (Disability) Network - Kingsweb

Gender Reassignment

x There is no current data on disciplinary cases involving gender reassignment. Any incidents of misconduct related to transphobic behaviour will be handled under this policy. Staff undergoing or having undergone gender reassignment will be supported sensitively and equitably.

Disciplinary Policy and Conduct Standards Page 31 of 39 What are the potential impact/s of implementing this policy, project, function or service on people who share protected characteristics as listed below?

Protected Characteristic: Neutral

Ongoing training for panel members should include awareness of trans equality issues , which is offered as part of the "other" Diversity and Inclusion training available in the Trust.

Staff can access support via King's and Queers network King's And Queers (LGBTQ+ Network) - Kingsweb

Marital Status (Married and Civil Partnerships)

x This policy applies equally regardless of marital or civil partnership status. There is currently no data available regarding disciplinary action by marital status. Pregnancy and Maternity x This policy recognises that disciplinary processes must not be affected by pregnancy or maternity. Employees absent due to pre gnancy related illness should have hearings rescheduled accordingly. They must also be given equal opportunity to respond to allegations. Ensuring non -discrimination during and after maternity leave is a key aspect of fair practice. Disciplinary Policy and Conduct Standards Page 32 of 39 What are the potential impact/s of implementing this policy, project, function or service on people who share protected characteristics as listed below?

Protected Characteristic: Neutral

Race (All Racial Groups)

x This policy promotes fairness for all racial groups and encourages diverse disciplinary panels. It seeks to ensure that no employee is disadvantaged based on race. However, available data often shows overrepresentation of some ethnic minority groups in formal disciplinary action. Workforce Composition for Race: - Ethnic Minorities: 58% - White 37% - Not Stated: 5% Based on the data for the number of disciplinary cases in a 12-month period, April 2024 - March 2025, There were 73 disciplinary cases in total. Ethnicity was recorded as: - Ethnic Minorities - 53 cases (72.6%) - White - 16 cases (21.9%) - Not stated 4 - cases (5.5%) Ethnic minority staff are significantly overrepresented in disciplinary cases, making up 58% of the workforce but nearly 73% of disciplinary cases. White staff are underrepresented, comprising 39% of the workforce but only 22% of disciplinary cases. Staff can access support via the REACH network All actions are outlined in the ERA action plan King's Race, Ethnicity and Cultural Heritage Network - Kingsweb Religion or Belief

x This policy should be applied equally regardless of religion or belief. Adjustments may be required for religious observances (e.g. scheduling hearings outside of religious holidays). Panel members should be aware of and sensitive to religious and cultural differences. Staff can access support via the Interfaith and Belief network Inter Faith & Belief Network - Kingsweb Disciplinary Policy and Conduct Standards Page 33 of 39 What are the potential impact/s of implementing this policy, project, function or service on people who share protected characteristics as listed below?

Protected Characteristic: Neutral

Sex (Men and Women Includes non-binary)

x All employees, regardless of sex or gender identity, are covered equally. This policy also supports the development of diverse panels to ensure balanced perspectives. Workforce Composition for Gender: - Female: 75% - Male: 25% Based on the data for the number of disciplinary cases in a 12-month period, April 2024 - March 2025, there were 73 disciplinary cases in total. - Female: 36 cases (49.3%) - Male: 37 cases (50.7%) There is a significant gender disparity. Male staff are twice as likely to face disciplinary action when compared to their female colleagues, proportionally. Males make up only 25% of the workforce but account for over 50% of disciplinary cases. Disciplinary Policy and Conduct Standards Page 34 of 39 What are the potential impact/s of implementing this policy, project, function or service on people who share protected characteristics as listed below?

Protected Characteristic: Neutral

Sexual Orientation (Lesbian, Gay, Asexual, Bisexual, and Straight)

x The policy promotes an inclusive environment where all sexual orientations are respected. Any homophobic conduct will be investigated appropriately. Workforce Composition for sexual orientation: - Bisexual 1.66% - Gay/Lesbian 3.12% - Heterosexual 80.62% - Not stated 12.96% - Blank 1.65% Based on the data for the number of disciplinary cases in a 12 month period, April 2024 - March 2025, there were 73 disciplinary cases in total. Sexual orientation was recorded as: - Bisexual 4 (5.48%) - Gay/Lesbian 3 (4.11%) - Heterosexual 55 (75.34%) - Not stated 10 (13.7%) - Blank 1(1.37%) Bisexual staff are significantly overrepresented: They make up just 1.66% of the workforce but account for over 5% of disciplinary cases. Gay/Lesbian employees also appear slightly overrepresented. Heterosexual employees are proportionately represented. There is potential disproportionality, especially for bisexual employees, in disciplinary outcomes. Staff can access support via King's Able Network King's And Queers (LGBTQ+ Network) - Kingsweb

Including but not limited to social economic factors (i.e. poverty and or isolation), caring responsibility, unemployment, homelessness, urbanisation, rurality, health inequalities, and new arrivals .

Socio-Economic Status x This policy ensures that all employees are treated fairly and consistently, regardless of socio economic background. Having a fair procedure protects staff in lower banded roles who may otherwise feel vulnerable to bias or lack of representation. Continued training for managers and transparent application of the policy will support equity. Caring responsibility x Employees with caring responsibilities may need flexible arrangements for attending hearings or meetings. Reasonable adjustments such as rescheduling or remote attendance options should be provided. Awareness training for managers will help ensure that carers are not disadvantaged during proceedings. Unemployment x While this policy does not directly cause unemployment, it outlines procedures that could lead to dismissal if misconduct is proven. To ensure fairness, all employees will be supported through representation, access to occupational health, and opportunities to respond to allegations before decisions are made. New arrivals x This policy applies equally to all staff, including internationally recruited or newly arrived employees. Language support, cultural awareness, and accessible communication should be provided to ensure understanding of the process and rights during disciplinary proceedings. Diversity in panel composition is also encouraged under this policy.

ERA Action Planning Form Action Plan Owner: Seyi Fadiora Commencement date: July 2025

ER Team 3 months Oct 2025 No data captured on age pertaining to disciplinary cases

ER tracker to capture age related data for number of disciplinary cases ER Team 3 months Oct 2025 Religion and belief Provide reasonable accommodations ER Team 6 months Oct Disciplinary Policy and Conduct Standards Page 37 of 39 and adjustments for employees observing religious or faith-based events, practices or observances. 2025

FOR EQUALITY DIVERSITY AND INCLUSION TEAM Date of Assessment: (dd/mm/yyyy)

17th June 2025

Jessy Ahluwalia, EDI Lead Date of review