Please find listed below our Group Policies, you can download each policy using the links below.

Should you have any questions regarding any of our Group Policies please email - [email protected] 




1.1  The Group is committed to ensuring that its internal organisation, suppliers, contractors, and other parties active within the Group’s supply chain adhere to the Ethical Base Code (Code of Labour Practice) attached at Enclosure 1. The Group’s commitment will be policed via the Labour Standards Assurance System (LSAS): a range of policies, procedures and practices employed to identify labour standard abuses, mitigate risks, and drive continual improvement.

1.2  Many of these procedures are already embedded within our organisation and indeed our supply chain. However, it is incumbent that current practice is identified, recorded, and managed with a view to continual review and improvement. This Paper details current internal & wider supply chain management procedures, and future targets for improvement.


 2.1  Board Responsibilities.     Ultimate responsibility for the Group’s Ethical Practice rests with the Board of Directors, with its management delegated to the Operations Director. Ethical Practice is reviewed as a specific agenda item at Board meetings, supported by an annual LSAS Status Report issued to all Directors.

 2.2  Training & Awareness.     All new staff are issued with an Arrival Pack when they join the company which refers then directly to the Group’s Ethical Practice commitment. This Policy Paper and the Ethical Base Code are displayed on the notice boards. In addition, all key Buying Department staff Training & Development Plans, list Ethical Base Code Awareness as a core competency.


 3.1  Internal Position.     Internally, the Group has active & long-established health & safety, and training & development procedures in place and ISO 9001 (2015)/ISO14001 accreditation. We have appointed a new consultant who brings a wealth of knowledge of both ISO and health & safety procedures. Moreover, clear disciplinary, grievance, consultation and equal opportunities procedures are laid down in our Policies & Procedures document which is issued to all staff when they commence employment and is readily available to all staff via our internal server.

3.2  Supply Chain.     The Group currently uses and maintains an LSAS file on each of its overseas suppliers. The file records current LSAS status, specifically identifying what audit procedures they have in place, copies of their last audit reports and a record of the on-going improvement action required by the Group. There is currently no specific requirement to move to Level 4 LSAS compliance by the NHS. An update on each overseas supplier is presented via the bi-annual LSAS Status Report to the Directors.

3.3  External Monitoring of Global Ethical Standards.   The Group keep abreast of changes in International Law, standards, and procedures via the Consultancy, IMPACTT and ETI. IMPACTT and ETI work closely with governments, academics & NGOs to maximise the positive impact of global trade on workers & local communities. The Group receives Newsletters from both organisations.


4.1 Immediate & Intermediate Targets.     The Group secured Lloyds Register Quality Assurance (LRQA) approval for LSAS Level 3 in June 2018. Continued compliance will be determined by an external audit with all subsequent Report recommendations and actions being pursued diligently. In line with NHS Supply Chain requirements, we will maintain Level 3 LSAS compliance whilst working with our supply chain in making continued improvements. Further internal audits will be undertaken by the Group’s contracted ISO/Health & Safety consultant. A Risk Assessment of our exposure to Labour Standard Issues is maintained and reviewed every year by the Operations Director. Commitment continues to improve our carbon footprint, we recently introduced a product range manufactured in recycled polyester and a new range, Landau Forward, is being launched in January which is manufactured from CiClO polyester which is biodegradable. Work also continues with our outside Consultant on improvements we can make as a business in this area.

 4.2 Supplier & Service Level Agreement Commitment.     Ethical Practice will be an agenda item on all future meetings between buying staff and our suppliers. Upon review or initial establishment, a clear commitment to LSAS will be part of all future Service Level Agreements.

 4.3 Internal Staff Training Commitment.     In addition, to their initial Awareness training, Buying Department management and key staff will receive further comprehensive training on the Ethical Base Code and its administration through LSAS.


5.1       The Board of Directors has a moral and legal obligation to ensure the implementation, management, and continual improvement towards the Ethical Base Code, and is subsequently committed to maintaining its LSAS status.




1. Employment is freely chosen 1.1 There is no forced, bonded or involuntary prison labour. 1.2 Workers are not required to lodge "deposits" or their identity papers with their employer and are free to leave their employer after reasonable notice.

2. Freedom of association and the right to collective bargaining are Respected 2.1 Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.
2.2 The employer adopts an open attitude towards the activities of trade unions and their organisational activities.
2.3 Workers representatives are not discriminated against and have access to carry out their representative functions in the workplace.
2.4 Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining. <ul?

3. Working conditions are safe and hygienic
3.1 A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.
3.2 Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers.
3.3 Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided.
3.4 Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.
3.5 The company observing the code shall assign responsibility for health and safety to a senior management representative.

4. Child labour shall not be used
4.1 There shall be no new recruitment of child labour.
4.2 Companies shall develop or participate in and contribute to policies and programmes which provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until no longer a child; “child” and “child labour” being defined in the appendices
4.3 Children and young persons under 18 shall not be employed at night or in hazardous conditions.
4.4 These policies and procedures shall conform to the provisions of the relevant ILO standards.

5. Living wages are paid
5.1 Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher. In any event wages should always be enough to meet basic needs and to provide some discretionary income.
5.2 All workers shall be provided with written and understandable Information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid.
5.3 Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

6. Working hours are not excessive 6.1 Working hours must comply with national laws, collective agreements, and the provisions of 6.2 to 6.6 below, whichever affords the greater protection for workers. Sub-clauses 6.2 to 6.6 are based on international labour standards.
6.2 Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per week.
*6.3 All overtime shall be voluntary. Overtime shall be used responsibly, taking into account all the following: the extent, frequency and hours worked by individual workers and the workforce as a whole. It shall not be used to replace regular employment. Overtime shall always be compensated at a premium rate, which is recommended to be not less than 125% of the regular rate of pay
6.4 The total hours worked in any seven-day period shall not exceed 60 hours, except where covered by clause 6.5 below.
6.5 Working hours may exceed 60 hours in any seven-day period only in exceptional circumstances where all the following are met: • this is allowed by national law. • this is allowed by a collective agreement freely negotiated with a workers’ organisation representing a significant portion of the workforce. • appropriate safeguards are taken to protect the workers’ health and safety. • the employer can demonstrate that exceptional circumstances apply such as unexpected production peaks, accidents, or emergencies. 6.6 Workers shall be provided with at least one day off in every seven-day period or, where allowed by national law, two days off in every 14-day period. * International standards recommend the progressive reduction of normal hours of work, when appropriate, to 40 hours per week, without any reduction in workers’ wages as hours are reduced.

7. No discrimination is practised
7.1 There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.

8. Regular employment is provided
8.1 To every extent possible work performed must be based on recognised employment relationship established through national law and practice.
8.2 Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour-only contracting, sub- contracting, or homeworking arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment.

9. No harsh or inhumane treatment is allowed
9.1 Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited. The provisions of this code constitute minimum and not maximum standards, and this code should not be used to prevent companies from exceeding these standards. Companies applying this code are expected to comply with national and other applicable law and, where the provisions of law and this Base Code address the same subject, to apply that provision which affords the greater protection.

Date: October 2022



TThe aim of this environmental policy is to provide additional focus of the company towards the environment. Grahame Gardner Ltd/Gymphlex Ltd is committed to embedding environmental sustainability within its operations. However, we recognise that our activities can have adverse environmental impacts through our routine daily undertakings.

Grahame Gardner Ltd/Gymphlex Ltd has committed to working to maintaining a certified Environmental Management System (ISO 14001:2015). We will ensure that we comply with all applicable environmental laws, standards, and compliance obligations; prevent pollution and continually improve our environmental performance.

The management & staff have a responsibility to engage with our commitment to environmental sustainability in order to achieve our environmental goals.
Our EMS provides a framework for setting environmental objectives, targets, timelines and resources to deliver these commitments. Effectiveness of our EMS will be regularly reviewed to enhance environmental performance.

Understanding the context of Grahame Gardner Ltd/Gymphlex Ltd's business activities, and recognising the environmental impacts of the operations, core areas we will focus on are:
Waste: Reduce, reuse and recycle materials to the greatest extent
Energy: Monitor, reduce and report our energy consumption
Paper: Monitor, review processes to reduce consumption of natural resources
Travel: Drive the efficiency of travel reducing fuel consumption for field operatives
Purchasing: Adopt purchasing policies which promote environmental sustainability
Engagement: Raise awareness of our environmental commitment amongst staff and keystakeholders with a view to support adoption of positive environmental behaviours. It is the responsibility of all the Management to ensure the above policy is understood and implemented at all levels of the organisation.



Grahame Gardner Ltd/Gymphlex’s policy is to operate in a manner which preserves health, safety and a sound environment.
Our aim is to ensure legislative compliance, and, where practicable, exceed this minimum requirements by incorporating sound health, safety and environmental management policies and practice into the work of all departments within our business.

Because of Grahame Gardner/Gymphlex Ltd's overall commitment to preserve health, safety and a sound environment, the company will:

  • Strive to comply with both the requirements and the spirit of, the “Health and Safety at Work etc. Act 1974”, “Management of Health and Safety Regulations” and all Regulations and Codes of Practice made under this act, in particular the duties imposed under the “Management of Health and Safety at Work Regulations 1999”."
  • Adopt management systems that will aim to protect the health, safety and welfare of all employees and other persons who may be affected by our work activities.
  • Take the necessary steps to ensure that safe systems of work are implemented and that all work equipment is properly maintained and operated in a safe manner.
  • Maximise employees’ involvement in health, safety and environmental matters by effective communication and encouraging their active participation
  • Appoint competent people as necessary to assist the management in meeting statutory duties including, where appropriate, appointing specialists from outside the organisation.
  • Provide sufficient resources in terms of people, training, and equipment to meet its health, safety and environmental commitments.
  • Set targets, objectives for improving health and safety at work and environmental protection, carry out regular internal assessments and report annually on performance.

This Policy and the way in which it is implemented will be reviewed regularly and at least annually on a formal basis and will be revised and updated as necessary.


Quality Policy

Grahame Gardner / Gymphlex company will develop, maintain and improve its management system and resources to ensure that products meet agreed customer needs and expectations. This company undertakes to supply only safety equipment that fully complies with the standards and regulations and claims made relating to those products. Where appropriate, this company will maintain up to date technical files and associated documentation to ensure that regulatory compliance information can be supplied upon request.
The quality assurance system has been developed to comply with the requirements of ISO9001:2015.
To achieve this, management will ensure that: -

  • Quality objectives are established, which are reviewed for continuing suitability.
  • There is a strong commitment to continual improvement in product quality and company performance.
  • There is a strong commitment to meeting customer requirements, which are communicated within the company via awareness programmes.
  • All activities are carried out under controlled conditions.
  • All employees are trained and competent to carry out the tasks assigned to them. Management shall ensure that this policy is understood, implemented and maintained at all levels of the organisation.

A current issue of this policy will be posted on all notice boards.

The quality system and procedures defined in the Quality Manual will be audited at specified intervals to ensure that what has been documented is being carried out in practice.

Furthermore, all systems procedures and practices will be reviewed by top management periodically to ensure effectiveness and capability to meet any changing requirements, including complying with legal requirements.

Signed: James Greenlees CEO Dated: Sept 2022 (Review Sept 2023)




1.1 This policy applies to all workers and employees working for Ryland Dickson Limited or any company which is a subsiiary or holiday company of Ryland Dickson Limited ("the Company") in the UK.

1.2  This policy does not form part of any employee's contract of employment and it may be amended at any time.


2.1  This policy is designed to enable employees of the Company to raise concerns internally and at a high level and to disclose information which the individual believes shows malpractice or impropriety. This policy is intended to cover concerns which the employee reasonably believes are in the public interest and may at least initially be investigated separately but might then lead to the invocation of other procedures (such as the disiplinary procedure).


3.1  Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work. This may include:

(a)    Criminal Offences

(b)    Failure to comply with any legal obligations

(c)    Miscarriages of justice

(d)    Damage to the environment

(e)    Dangers to the Health & Safety of any individual

(f)    Modern day slavery or human trafficking concerns within the Company or its supply chain

(g)    Attempts to conceal any of these

3.2  A whistleblower is a person who raises a genuine concern relating to any of the above. If you have any genuine concerns related to suspected wrongdoing or danger affecting any of our activities (a whistleblowing concern) you should report it under this policy.

3.3  This policy should not be used for complaints relating to your own personal circumstances, such as the way you have been treated at work. In those cases you should use the Grievance Policy or Anti-harassment and Bullying Policy as appropriate.

3.4  If you are uncertain whether something is within the scope of this policy you should seek advice from a senior member of management.


4.1  We hope that in many cases you will be able to raise any concerns with your line manager. However, where you prefer not to raise it with your manager for any reason, you should contact a senior member of management who will arrange a meeting with you as soon as reasonably to discuss your concern.


5.1  We hope that staff will feel able to voice whistleblowing concerns openly under this policy. We do not encourage staff to make disclosures ananymously. Proper investigation may be more difficult or impossible if we cannot obtain further information from you. It is also more difficult to establish whether any allegations are credible. If it is necessary for anyone investigating your concern to know your identity, we will discuss it with you.


6.1  Once you have raised a concern, we will carry out an initial assessment to determine the scope of any investigation. We will inform you of the outcome of our assessment. You may be required to attend additional meetings in order to provide further information. You should treat any information about the investigation as confidential.

6.2  In some cases we may appoint an investigator or team of investigators including staff with relevant experience of investigations or specialist knowledge of the subject matter. The investigator(s) may make recommendations for change to enable us to minimise the risk of future wrongdoing.


7.1  It is possible that whistleblowers are sometimes worried about possible repercussions. We aim to encourage openness and will support staff who raise genuine concerns under this policy.

7.2  Whistleblowers must not suffer any detrimental treatment as a result of raising a concern. Detrimental treatment includes dismissal, disciplinary actions, treats or othe unfavourable tratment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform Human Resources immediately. If the matter is not remedied you should raise it formally using our Grievance Policy.

7.3  You must not threaten or retaliate against whistleblowers in any way. If you are involved in such conduct you may be subject to disciplinary action which could result in your summary dismissal.

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