The Royal Opera House (ROH) aspires to highest standards of corporate governance and seeks to embed best practice in a series of policies that apply to its staff, freelancers and contractors. Some of our key corporate policies are summarised below.
Gender Pay Gap Reports
Anti-Bribery and Corruption Policy
The purpose of this policy and procedure is to provide clear guidance for the prevention and detection of bribery and corruption in the ROH. The Anti-Bribery and Corruption Policy applies to all staff, artists, casuals, freelancers, contractors or sub-contractors working for or on behalf of the ROH, or when working with third parties for or on behalf of the ROH. We recognize that an act of bribery or corruption is illegal, under the Bribery Act, 2010. It is our policy to conduct all of our business in an honest and ethical manner and we are committed to ensuring adherence to the highest legal and ethical standards, implementing and enforcing systems to counter bribery and corruption.
Data Protection Policy
Declaration of Interest Policy
This policy applies to Trustees, the Executive team and senior managers with procurement responsibilities and/or in receipt of hospitality and gifts. Trustees and senior staff of the ROH must ensure that their personal or business interests outside work do not conflict with those of the ROH. Accordingly we ask trustees and senior staff to declare their interests (and any gifts or hospitality received over £50) in connection with their role in the ROH. A declaration of interests form is provided for this purpose and the declaration of interests form needs is updated annually.
Policy on Accepting Sponsorship, Donations and Membership
The Royal Opera House is grateful for all funding received in furtherance of its charitable objects.
The ROH is committed to following fundraising best practice and the Fundraising Regulator's Code of Fundraising Practice. The ROH undertakes to comply with relevant law and regulations, including the Proceeds of Crime Act 2002, the Money Laundering Regulations 2007 and the Bribery Act 2010, data protection law, tax and Gift Aid legislation and Charity Commission guidance, as well as its own corporate policies.
Ultimate responsibility for accepting or declining funding lies with the Board of Trustees, as the ROH's governing body. The Board has a duty to act at all times in the best interests of the ROH as a charity, including when deciding whether to accept or decline offers of funding. The ROH has established policies and procedures on the acceptance of funds and may conduct due diligence research on prospective sources of funding (including individuals). While each case is considered individually, funding will be declined where it might cause the ROH to breach its legal obligations or be detrimental to the achievement of the ROH's charitable purposes.
Should the Board determine to decline support it would follow Charity Commission Guidance, and where appropriate seek Charity Commission advice.
Ultimate responsibility for the rejection, acceptance and return of funding lies with the Board of Trustees. Day-to-day responsibility for assessing potential donations and corporate partnerships for compliance and risk is delegated to the Development team who report to the Board on a regular basis. A sub-committee of the Board, the Ethics Committee, is responsible for monitoring compliance with the Board’s policy on accepting funds.
The Ethics Committee comprises:
- Senior Independent Director
- Trustee with legal expertise
- Chief Executive Officer
- Director of Development and Enterprises
- Director of Audiences and Media
Final decisions may be referred to the Board. Where appropriate the Board may seek external advice, including from the Charity Commission.
Any data collation will be carried out in full compliance of the Data Protection Act 1998 and General Data Protection Regulation (GDPR). This includes maintaining confidentiality and keeping information for time limited periods. Fundraising communications will be conducted in accordance with the Privacy and Electronic Communications Regulations 2003 and any applicable direct marketing guidance issued by the ICO or Fundraising Regulator.
For further information on how we process personal data, including prospect due diligence, managing contact with donors and the impact of new legislation, please see the ROH Privacy Statement.
Policy on Accepting Sponsorship, Donations and Membership approved by the Board on 29 May 2018.
This policy ensures that the ROH Group has a clear expenses framework that balances consistency with the flexibility to meet the employee and the ROH Group’s needs. It is the ROH’s intention that employees should neither lose nor gain financially as a result of incurring expenditure on ROH business. It also sets out the procedures to be adopted when making a claim for payment.
Fraud Policy and Procedure for Investigation
The purpose of this policy and procedure is to provide clear guidance for the prevention and detection of fraud to ensure that the assets of the ROH are safeguarded. The ROH encourages a culture of honesty, reliability and trustworthiness throughout the organization and is committed to ensuring that opportunities for fraud are minimized.
Health and Safety Policy
This policy set out the steps taken by the ROH to ensure the health, safety and welfare of its employees and visitors to its premises, in according the Health and Safety at Work etc. Act 1974 and the Management of Health and Safety at Work Regulations 1999. To this end the ROH requires all visitors to comply with its House Rules and accepted codes of conduct. In terms of governance, the Health and Safety Committee provides the formal forum for consultation on health and safety matters with the recognized Trade Unions. It is supported by the Health and Safety Management Group, which directs the programme of health and safety activity within the organization.
Modern Slavery and Human Trafficking Statement
Section 54 of the Modern Slavery Act 2015 requires certain organisations to develop a slavery and human trafficking statement each year. The Royal Opera House is a large organisation for these purposes and welcomes the opportunity to state very clearly its policy in these respects.
The Royal Opera House unreservedly condemns modern slavery and human trafficking wherever in the world it occurs.
The steps we have taken to ensure that they are not taking place in our business or supply chains are as follows:
- We have prepared and formally adopted the Royal Opera House Modern Slavery and Ethical Sourcing Policy
- We have assessed our supply chains and will continue to be vigilant in making decisions regarding our suppliers and potential suppliers by seeking confirmations and commitments as to the absence of these practices in their businesses
- We will withdraw from existing contracts (where we may lawfully do so), or decline to enter into or renew a contract with a supplier or potential supplier, if our counterparty is unable to give us sufficient confirmations and commitments
The Royal Opera House is required to publicise annually, on its website, its activities over the latest financial year aimed towards the eradication of modern slavery and human trafficking. This is our third statement of activities to be posted on our website. During the past year we have:
- Raised awareness via internal briefings, particularly with those staff engaged in departments identified as high risk
- Engaged with high-risk suppliers through our own questionnaire for response on areas such as compliancy to the Act, risk assessment in supply chains, training of staff and internal policies
- Supplemented our knowledge on Modern Slavery through dialogue with The Ethical Trading Initiative and formal Modern Slavery training from the Chartered Institute of Purchase and Supply (CIPS)
- Agreed a Modern Slavery side letter to the contract with our facilities management provider, including cleaning and security staff
- Continued to track progress via a centralised register, including preparation of plan for the next year, which includes a review of our work in this area by internal audit
Should there be any questions or concerns as to the implementation of these requirements, please direct them to the Director of Finance. If any staff are concerned that modern slavery or human trafficking is taking place in our business or supply chains they should raise their concerns to the Director of Finance or through the Whistleblowing policy.
Procurement Policy and Authorized Signatory Limits
The ROH is committed to best practice in the procurement of goods and services, and has particular obligations in this regard as an Arts Council England National Portfolio Organization. This policy sets out the principles which the ROH seeks to adhere to in procurement activities, including pursuing Value for Money (VfM), promoting environmental and social sustainability, encouraging transparent and fair competition, and adhering to ethical standards.
Records and Document Management Policy
This policy sets out the ROH’s commitment to managing records and documents in accordance with five key principles. These principles are that reliable records must be created in accordance with common standards, information must be shared rather than managed as a personal resource, access to confidential information must be restricted, information must be organized in a logical and consistent way and records must be retained for agreed periods of time. In accordance with the final principle, appropriate records must be passed to our Collections department to provide a historical record of the organization’s work.
Safeguarding Children and Young People (Policy and Procedure)
In this policy and procedure the ROH sets out its commitment to protecting the safety and welfare of children in its care, and to ensuring that its members of staff are kept informed, supported and protected from unfounded allegations of abuse. To these ends, the ROH operates within the City of Westminster safety guidelines for children in stage performances, and adheres to effective procedures for recording and responding to incidents, complaints and alleged or suspected incidents of abuse. Within their overall health and safety management responsibilities, the Director of Personnel has primary responsibility for child protection. This is supported by a Child Protection Committee, which oversees the policy and procedure.
Whistleblowing Policy and Procedure for Investigation
Hotline: 0800 374199
The ROH encourages all members of staff to raise any concerns that they may have about the conduct of others in the organization in relation to any suspected instances of fraud, misconduct or wrongdoing. This policy sets out the ROH’s position in these matters and lays out a procedure for individuals to raise any concerns and how those concerns will be dealt with. The procedure applies to all employees, casual staff, contractors and freelance staff.
Bullying and Harassment Policy
All individuals have the right to work without fear of harassment or abuse, whether on the grounds of sex, race or colour, disability, sexual orientation, age, religion, trade union membership or duties or indeed any ground. It is the Royal Opera House policy to make every effort to provide a working environment free of harassment and intimidation. Harassment may constitute unlawful behaviour. It is also improper and inappropriate behaviour that lowers morale and interferes with work effectiveness. It makes the work environment threatening. Such behaviour is unwelcome and unacceptable. It is against the policies of the Royal Opera House for an employee to harass another employee. Such conduct will not be condoned or tolerated. Whilst the implementation of the policy is the duty of the managers and supervisors, all employees are expected to comply with this policy and take appropriate measures to ensure that such conduct does not occur. Appropriate disciplinary action, including dismissal for serious offences, will be taken against any employee who violates this policy.