Disciplinary policy

Contents

1 Introduction

This policy provides a process for the management of alleged misconduct and the associated implications of the pay progression framework. Separate procedures apply for the management of performance issues and absence as a result of sickness (full details of these are given at section 13).

The policy contains a two stage approach: an informal and formal stage. It is the trust’s policy to ensure that any disciplinary matter is dealt with fairly and that steps are taken to establish the facts and give employees the opportunity to respond before taking any formal action, if required. Where appropriate, managers will aim to resolve conduct issues at the informal stage. Where conduct is related to a breakdown in working relationships; mediation may be an appropriate option to explore.  

The policy also provides an appeal mechanism for employees to seek a review of decisions involving formal warnings or dismissal.

This policy and procedure complies with all relevant legislation and the principles set out in the advisory, conciliation and arbitration service (ACAS) Code of Practice on Disciplinary and Grievance Procedures, 2015. (opens in new window)

2 Purpose

The purpose of this policy and procedure is to provide a non-discriminatory, fair and timely process for the management of disciplinary matters within the trust.

This policy and procedure should not be viewed primarily as a means of imposing sanctions; its key purpose is to encourage improvements in individual conduct or capability.

3 Scope

This policy applies to all employees employed by the trust, regardless of length of service, including bank workers.

The investigation of personal and professional conduct, capability and Ill health concerns involving medical and dental staff will be undertaken in accordance with the national framework set out in maintaining high professional standards in the modern NHS (2005) (opens in new window). Where personal conduct issues are identified they will then be managed under this policy and procedure. If an employee feels it is inappropriate for the trust’s disciplinary policy to be applied in an individual case, they should access the trust’s grievance policy.

For those employees subject to a live disciplinary sanction incremental pay step progression will be deferred.

For advice on the applicability of this policy and procedure to employees who have transferred to the trust in accordance with the Transfer of Undertakings (Protection of Employment) 2006 (as amended by the Collective (opens in new window)

Redundancies and transfer of undertakings (protection of employment) after the approval date of this policy, please consult the trust’s human resources department (opens in new window).

Seconded employees are covered by the policies of their employing organisation unless the secondment agreement states otherwise.

4 Responsibilities, accountabilities and duties

4.1 Board of directors

The board of directors has overall responsibility for ensuring that this policy is applied fairly, consistently and in a non-discriminatory manner.

4.2 Managers

Managers are responsible for ensuring that all employees are aware of this disciplinary policy and associated procedure. Each employee should be informed of the standards of conduct and work performance expected in their job as well as the implications of failing to meet these expectations on their incremental pay-step progression.  Managers will refer new employees to this document as part of their local induction and encourage them to familiarise themselves with its contents.

Managers have a duty to apply this policy fairly and consistently, and to act in accordance with the schedule of delegated authority, which can be found at appendix A. Managers have a duty to seek advice from the human resources department or Medical Staffing team if they are considering taking action against an employee under the formal stage of this procedure.

4.3 The human resources department

The human resources department or medical staffing teams are responsible for providing legally sound advice and guidance to managers on the application of this policy and must be involved in all action taken under the formal stage of the disciplinary procedure.

Human resources or medical staffing colleagues who provide advice and guidance to managers on the application of this policy are responsible for ensuring that they maintain current knowledge of applicable employment law and best practice and have a duty to seek advice from a more senior member of the Human Resources team or medical staffing function if they are unsure.

The human resources department has a duty to monitor the application of the formal stage of the disciplinary procedure, in order to ensure that it is being applied in a timely and non-discriminatory manner and in accordance with the Equality Act 2010.

4.4 Employees

Employees are responsible for maintaining appropriate standards of conduct and acting within their level of competence seeking advice from their manager if they are unsure. Where appropriate, employees are responsible for upholding the standard of their professional body.

Employees have a duty to act in accordance with trust policies and procedures, and to familiarise themselves with these documents.

Employees are expected to attend disciplinary meetings and appeal hearings, unless there are extenuating circumstances which would prevent attendance.

4.5 Staff side or professional organisation representatives

Trade union or professional organisation representatives will:

• ensure that they familiarise themselves with this policy and procedure
• advise members in accordance with the policy and procedure
• assist employees in preparing a written statement or attend investigatory meetings if required, encourage them to provide a clear explanation of the concern with supporting evidence wherever possible

Throughout this policy, the term “union” or “trade union” should be taken to include professional organisations.

5 Procedure or implementation

5.1 Informal action

This is not part of the formal disciplinary procedure. However, where this informal stage is used, a note will be made and retained on the employee’s personal file to record the discussion and any action taken. This informal stage would be appropriate to address minor misconduct or minor carelessness as these cases are usually best dealt with informally, encouraging reflection and learning. In some cases, additional training, coaching and advice may be appropriate.

An informal action note template form can be found in the disciplinary toolkit.

The objective of this informal stage is to remedy the matters of concern, and formal action should follow only where it becomes apparent during the discussion that the matter is more serious than was initially apparent, or where the issues discussed persist following the discussion. Employees should therefore be informed at the commencement of this process that whilst ever the initial stages are informal, any information provided by employees at this stage may be used going forward if it is decided that more formal proceedings are required.  

At this stage, it is not necessary to involve the employee’s union representative or a human resources representative, as this is not a formal process, but the employee may wish to contact their representative for advice.

During discussions at the informal stage, employees will be made aware that, if the issues discussed persist or recur, formal disciplinary action could be taken. They will also be asked whether they require any support from the trust in order to improve.

Should it be deemed appropriate for issues which have been resolved informally to be referred to within a subsequent formal process, the employee and their representative will be informed. Any reference to previous informal issues should only be made when they are relevant to the issue in question.

5.2 Personal responsibility framework (informal)

The personal responsibility framework is a framework for managing conduct and behavioural issues outside a disciplinary process. The personal responsibility framework is not designed to replace this policy and procedure but may be used to deal with issues and concerns which are not classified as potential gross misconduct issues or where the informal stage has not proved to be successful.

Under the framework an employee, in conjunction with their manager, accepts personal responsibility for their actions and commits to an action plan to modify and change their behaviour. This process is also used to improve quality and to learn from mistakes, as managers and employees take an equal share of the responsibility for the things that happen around them.

A personal responsibility framework standard operating procedure can be located at appendix D in the disciplinary toolkit

5.3 Preliminary investigations (fact-finding)

Where a potential disciplinary matter arises, depending on the circumstances it may be necessary for the manager responsible for the service in question (unless they are directly involved in the allegation, in which case an independent person should be assigned) to carry out some preliminary investigations, following consultation with the Human Resources team to establish the facts promptly before recollection of events fade. This may include a request for a written statement. A written record of any meetings should be kept.

Should an employee be asked to provide a written statement they should be given sufficient time to do so. Employees also have the right to discuss and share the statement with their trade union or professional organisation representative before submission to the trust. Guidance on providing a statement is contained in appendix B and will be issued to employees who are asked to make a statement.

An initial fact-finding template form can be found in the disciplinary toolkit.

A preliminary investigation meeting is purely for the purpose of establishing the facts of the case and it must be made clear to the employee involved that it is not a formal investigation or disciplinary meeting. The preliminary investigation should be completed as quickly as possible and normally no later than 2 working days from the concerns being raised, unless in exceptional circumstances or due to the absence of key witnesses. The preliminary investigation is not intended to be a full investigation but an initial fact-finding exercise in order to determine whether any further action and or formal investigations are required. The manager responsible for preliminary investigations should keep in regular contact with their Human Resources representative regarding processes.

Having established the facts, the manager may decide:

• that there is no requirement to pursue the matter further
• that the matter can be dealt with under the informal action stage of this policy
• that the matter can be addressed through the personal responsibility framework
• to refer the matter to a senior manager recommending a formal investigation be commissioned by an independent investigator

5.4 Reasonable adjustments

In applying this procedure, managers and the human resources department will ensure that reasonable adjustments are made for employees; with disabilities or literacy difficulties, religious beliefs or culture or for whom English is not a first language, as appropriate to individual circumstances to ensure that these employees are able to fully participate in disciplinary processes. Where an employee who is facing disciplinary action, or who has been asked to act as a witness, feels that such adjustments are necessary, they should initially discuss the issue with their line manager or investigating officer.

5.5 Allegations and safeguarding

Where allegations regarding the safeguarding of children or vulnerable adults are made against an employee, the deputy director of nursing must be contacted immediately, prior to any investigation being undertaken. The deputy director of nursing (or deputy) will liaise with the investigating manager and human resources regarding the investigation process.

It is important to highlight that the trust has an active person in a position of trust (PIPOT) procedure with clear procedures to follow and will be led by the Safeguarding team.

Whilst the PIPOT guidance is concerned with potential harm to adults with care and support needs, if the allegation is such that there is a concern that the person may also pose a risk to children, then children’s services must be informed. It is everyone’s duty to refer any current and historical allegations of abuse against children to children’s services, whether the alleged perpetrator is a person in a position of trust or not. Concerns about children should be referred through to the local authority designated officer (LADO) following the local safeguarding children board (LSCB) procedures. This guidance should be applied when concerns are raised about a person in a position of trust in a work (professional) context and also if any relevant concerns arise from a person’s personal life, if there are implications for the safety of people with care and support needs. This guidance applies whether the allegation or concern is current or historical.

When considering a referral relating to a person in a position of trust, a distinction should be made between an allegation, a concern about a person’s quality of care or practice and a complaint.

Where there are potential risks to adults with care and support needs who use the trust’s services, these risks need to be assessed, and if necessary, action should be taken to safeguard those adults.

Historical allegations should be responded to in the same way as contemporary concerns. It will be important to keep an overview of whether allegations form a pattern, are repeated and may indicate organised abuse. For further information and procedures, please refer to the trust PIPOT procedure.

5.6 Cases involving counter fraud issues

Where allegations of fraud are made, the local counter fraud specialist (LCFS) must be contacted immediately, prior to any investigation (this includes both an informal and formal investigation) being undertaken. The LCFS will liaise with the manager and human resources regarding the investigation process. The contact details for LCFS are available on the Intranet. The LCFS may conduct an investigation in line with the fraud, bribery and corruption policy.

Allegations involving fraud are often very complex. Sometimes it will be possible to conduct a disciplinary investigation alongside a fraud investigation, whilst in other cases, it may be necessary to complete the fraud investigation prior to commencing any disciplinary investigation. The relevant care group director or corporate director should be involved in discussions about the coordination of disciplinary investigations, and has overall responsibility for ensuring that they are completed as efficiently as possible (although where the LCFS is involved in an investigation, and there is dispute around its coordination, the executive director of finance and performance must be consulted).

5.7 Suspension from work

In certain circumstances, employees may be suspended from work prior to and during a disciplinary investigation. Suspension is not a disciplinary measure.  It is without prejudice and is carried out in the interests of all parties (for example where working relationships have broken down or there is a risk to an employee’s or the trust’s property or responsibilities to other parties). A checklist to assist with the decision-making around whether to suspend and employee has been developed and is available in the disciplinary toolkit. Managers are requested to work through this checklist to ensure their decision and rationale for suspension are clearly documented.

Prior to suspending an employee, alternative arrangements such as assignment to other duties, change of work base or change of line manager will always be considered and, if appropriate, discussed with the employee. This should only be done where it does not compromise the investigation.

These alternative arrangements will be reviewed no less than every four weeks during the disciplinary investigation; this will be undertaken by the investigating officer and a HR representative, in order to determine whether the arrangements are still necessary and proportionate. Employees and if appropriate their representatives will be notified in writing the outcome of this review. If alternative arrangements become unworkable, or an employee refuses to agree to them, suspension may be the only option.

Examples of circumstances where suspension may be appropriate to include situations where:

• the misconduct being investigated is serious enough that, if substantiated, it may warrant summary dismissal on the grounds of gross misconduct
• there is a risk that, if the employee remains at work, they may interfere with the disciplinary investigation
• an investigation regarding suspected fraud or the safeguarding of children or vulnerable adults is being conducted
• an employee’s registration with their professional body has been suspended or is subject to conditions of practice (where an employee’s registration has lapsed, reference should be made to the policy for the verification of employees’ professional registration)
• the employee is the subject of a police investigation into allegations which may impact on their employment

Suspension does not apply to medical and dental employees, exclusions apply where appropriate. For the exclusion of medical and dental employees the maintaining high professional standards in the NHS framework should be applied and advice sought from the Medical Staffing team.

The purpose of suspension is to allow an unhindered investigation of the allegations that have been made. However, it is recognised that suspension may be stressful for the employee involved, and for this reason, all suspended employees will be encouraged to contact their staff side representative.

Suspended employees will also be offered access to counselling if appropriate.

The authority to suspend rests with the appropriate senior manager on duty at the time, however, they should attempt to obtain advice from the human resources department or on-call director before suspending.

Wherever possible, employees should be suspended in person. If the employee is not at work and all reasonable attempts to contact them at home fail then they will be informed in writing, sending two copies of the same letter by standard first class post and recorded delivery, informing the employee not to commence duty but to contact a named officer as a matter of urgency.

Alternatively, the suspending manager may wish to hand-deliver the letter to the employee’s home address.

An employee who is suspended must be informed clearly of the reasons for suspension, that suspension does not indicate a presumption of guilt and advised to contact their union representative if applicable. Following suspension, written confirmation of the suspension and the reasons for it must be sent to the employee as soon as possible and no later than the next working day after the suspension.

Any suspension should be regularly reviewed by the investigating officer in conjunction with the commissioning manager with the review confirmed in writing to the employee, and where relevant their representative, at least every four weeks in order to determine whether the arrangements are still necessary and proportionate. If alternative arrangements become unworkable, or an employee refuses to agree to them, suspension may be the only option.

A copy of the suspension review letter can be located in the disciplinary toolkit. If the original reasons for the suspension change or no longer apply, or an alternative arrangement becomes available, this should be discussed with the employee, who will be required to return to work if appropriate. The suspension checklist in the disciplinary toolkit should be updated to reflect all suspension reviews and any changes to the original suspension decision should be clearly documented in this checklist.

Where a period of suspension exceeds 12 calendar weeks, the case should be referred to the director of people and organisational development for their review. An explanation and an agreed action plan for the continuing period of suspension must be provided.

During a period of suspension, an employee should remain available for work with the trust and can reasonably be expected to attend meetings in normal working hours, unless a period of annual leave has been booked in advance of being notified of the meeting.  If an employee becomes too ill to work during a period of suspension, they should report this in the normal way, providing a statement of fitness to Work if their illness lasts for over seven calendar days. If an employee states that they are unable to attend meetings held under this procedure as a result of illness, they may be referred to

Occupational health for advice on when they are likely to be fit to participate in the process.

Suspension will normally be on full pay (which includes an average of the enhancements which an employee has been paid in the three months prior to their suspension).  However, if a suspended employee becomes ill, and occupational health advise they are unable to participate in the process as a result (or if the employee fails to attend occupational health in such circumstances), the employee will be paid occupational sick pay (where applicable). Where a suspended employee utterly fails to engage with the disciplinary process and does not maintain contact with the trust, the trust reserves the right to suspend all pay, although such a decision can only be taken by a manager at director level.

Whilst on suspension, normal rules regarding the booking and taking of annual leave apply, and suspended employees should continue to book and take annual leave as they would if they were not suspended. In common with employees who remain at work, suspended employees will not normally be able to carry over annual leave entitlement between financial years.

In order to allow for an unhindered investigation, suspended employees should not contact other employees of the trust (excluding their designated contact person and their trade union representative) or enter trust premises (unless attending meetings connected with their suspension of medical appointments). If a suspended employee wishes to contact another trust employee or enter trust premises for any other reason, they should seek permission from their designated contact person. Further, prompt action should be taken in response to the identified harm and its causes.

5.8 Investigations

The purpose of the investigation is to allow the trust to establish a fair and balanced view of the facts relating to any disciplinary allegations against an employee. The investigating officer must act impartially and independently of undue influence from others and make a recommendation on whether the case should be referred to a disciplinary hearing.

The provision of maintaining high professional standards apply to medical and dental investigations and further guidance should be sought from the Medical Staffing team.

The senior manager responsible for the service in question will appoint an investigating officer. The investigating officer will be supported by a named HR representative. Clear terms of reference, to ensure the investigation is appropriately limited, should be written for the case investigator which sets out the allegations to be investigated. The terms of reference should be reviewed on a regular basis by the case investigator and HR to ensure it is up-to-date. A disciplinary investigation terms of reference template is available in the disciplinary toolkit.

In the cases of potential gross misconduct, at a point in the investigation when the investigating officer is sufficiently informed, given the difficulty in accessing diary availability of disciplinary panel members it is advised that a disciplinary hearing date is provisionally arranged wherever possible, in conjunction with staff side diaries, without prejudice to the outcome of the case.

As far as possible the clear nature of the allegations or concerns should be confirmed in writing to the employee, thus ensuring that they are aware of the nature and extent of the investigation. The investigation will include requesting statements and interviewing the employee concerned and any witnesses, and the gathering of any documentary evidence to ensure that the investigating officer has a full understanding of all of the relevant information. In the event if significant difficulty in interviewing any of the witnesses, the rationale for not pursing the investigation with these particular witnesses should be detailed in the investigation report.

The employee should be updated, by the commissioning manager in writing, every four weeks on the progress of the investigation.

If further allegations or information comes to light during the course of the investigation, this may need adding to the terms of reference, or a separate investigation may be required. The case investigator should refer back to the commissioning manager for the investigation to agree if an adjustment to the terms of reference is appropriate, or if a separate investigation should be commenced. The employee must be informed in writing of any additional allegations or any amendments to the original allegations and how these will be investigated.

During the course of the investigation the employee must be given the opportunity to respond to all of the allegations or concerns which may mean that the employee is requested to attend an investigatory meeting on more than one occasion.

The audio or visual recording of investigation meetings is not permitted by the trust.

In all cases, investigations should be completed in a timely manner.  If, for any reason, an investigation is still ongoing twelve weeks after the alleged misconduct first came to light, the investigating manager will be required to notify the relevant director in writing of the reason for the delay.

It should be noted that, where an employee of the trust is asked to provide a witness statement, or to attend an investigation meeting as a witness, the trust regards this as a reasonable management request, which should be complied with. If an employee is requested as a witness, a guidance sheet will be made available by the investigating officer explaining the witness’s role within the disciplinary process and the expectations of the trust (see appendix B).

All employees, whether they are the subject of the investigation, are entitled to be accompanied by a companion. The chosen companion may be a fellow trust employee, a trade union or professional organisation representative or an official employed by a trade union or professional organisation. Employees may also seek advice from their companion if they are required to write or submit a statement as part of a disciplinary investigation. A companion must not be implicated or involved with the investigation therefore, the investigating officer must be informed in advance of the meeting if the employee chooses to bring a work colleague or staff side representative.

Where it is necessary to meet with any employee as part of an investigation, they will be informed of the meeting, its purpose and their right to representation in writing. The human resources department will liaise with the line managers of witnesses to ensure they also receive appropriate support.

5.9 Outcome of the investigation

On conclusion of the disciplinary investigation, the investigating officer will report their findings using the template disciplinary investigation report in the toolkit to the commissioning manager for consideration. The commissioning manager (who should not be part of the panel at any subsequent hearings wherever possible) will review the findings and conclusions and will make a recommendation on further action.

The options are:

• no further action, where there is no case to answer, or insufficient evidence, then no further action should be taken. The employee should be advised of this in writing and all records of the investigation removed from their personal file
• informal file note, this is an attempt to correct the problem and prevent recurrence without the need to resort to disciplinary proceedings
• personal responsibility framework, this is an attempt to correct the problem where there is evidence which highlights shared failings and associated learnings in respect of the misconduct. The employee in conjunction with their manager, accepts personal responsibility for their actions and commits to an action plan to modify and change their behaviour. This process is also used to improve quality and to learn from mistakes, as managers and employees to take an equal share of the responsibility for the things that happen around them
• proceed to a disciplinary hearing, where there is sufficient evidence of an issue of misconduct which warrants formal disciplinary action, then a disciplinary hearing should be convened, and the employee will be informed of this decision in writing

5.10 Raising a grievance during disciplinary proceedings

If an employee raises a formal grievance or a formal complaint of bullying or harassment during the course of a disciplinary case, consideration will be given to suspending the disciplinary procedure whilst the grievance or complaint is dealt with. Where the grievance and disciplinary cases are connected, it may be appropriate to deal with both issues concurrently. If an investigation concludes that the grievance or complaint was groundless and raised solely with the intention of avoiding or disrupting disciplinary action, the original disciplinary process will be resumed and consideration given whether further disciplinary action should be taken in relation to this matter.

5.11 Proposed action against a trade union or professional organisation representative

Although normal disciplinary standards apply to all accredited trade union representatives’ conduct as employees, any concerns should be discussed at an early stage with a full time official employed by the union, after obtaining the employee’s agreement.

5.12 Formal disciplinary action

Before any formal disciplinary hearing, the employee will be advised in writing of the allegations which will be considered at the hearing. All of the documents to be considered at the hearing will be enclosed with the letter and will provide details of any witnesses which management intend to call at the hearing. The employee will also be asked to confirm, in advance of the hearing, if they wish to call any witnesses.

The letter will also remind the employee of their right to be accompanied by a companion. The definition of a companion is detailed in Section 5.8. The letter will be sent to the employee at least seven working days before the date of the hearing. Should the disciplinary pack be of significance then wherever possible further time should be allowed to support preparation.  In order to facilitate staff side representation it is advantageous to provide as much notice as possible of the hearing date.

It is important to ensure that the disciplinary panel has the opportunity to resolve any conflicting accounts from witnesses in order to reach a view or decision. It is therefore advisable for the investigating officer to ensure all relevant witnesses attend the hearing to provide evidence.

If the employee wishes to call any witnesses at the hearing, they should inform the chair of the disciplinary panel who will make arrangements for their attendance, and inform the trust (if the employee is suspended, they should seek permission from their designated contact person prior to contacting any potential witnesses who are trust employees).

The chair of the panel should also review all of the information sent to the employee in preparation for the hearing.

The employee will be given the opportunity to state their case, question the investigating officer and any witnesses and make a closing statement.

The companion will be allowed to address the hearing to detail and summarise the employee’s case, respond on behalf of the employee to any views expressed at the hearing and confer with the employee during the hearing. The companion does not, however, have the right to answer questions on the employee’s behalf, address the hearing if the employee does not wish it or prevent the employee from explaining their case.

The chair of the panel will adjourn the disciplinary hearing to consider all of the information which has been presented, prior to reaching their decision. The expectation is that the disciplinary outcome is verbally communicated to the employee and their companion on the same day as the hearing. If this is not feasible then the hearing manager will provide an explanation and will agree the timescales and method of communication with the employee and their companion.

If there are any references to other employees or third parties, or to other issues not directly related to the employee who is subject to formal action in the material to be circulated, these may be removed prior to it being sent out, in the interests of confidentiality.

The audio or visual recording of disciplinary hearings is not permitted by the trust.

5.13 Re-scheduling of disciplinary hearings

If an employee fails to attend a disciplinary hearing, either because their representative is unavailable, or for any other reason, the hearing will be rescheduled to a date within two weeks of the original date. Where possible, this re-scheduling will occur in consultation with the employee’s representative, in order to ensure their availability. The letter requiring the employee to attend the re-scheduled hearing will clearly state that, should the employee fail to attend, the hearing will be conducted in their absence.

Should an employee fail to attend a re-scheduled hearing, the manager hearing the case will give consideration to the reasonableness of any explanation given in advance for the non-attendance, but may consider proceeding to hear the case in the employee’s absence and proceed based on the facts available at the time. The employee will be informed in writing of the outcome of the hearing unless there are compelling reasons not to do so.

6 Requesting a disciplinary sanction without attending a formal hearing

Where an employee has been subject to a formal disciplinary investigation and has been notified that the case is to be referred to a disciplinary hearing, the employee has the option to request that a formal disciplinary sanction is applied without attending a formal hearing.

If a staff member submits a request for this and if the request can be accepted the manager will confirm this in writing, usually within seven working days, informing the employee of the level of sanction to be applied and, the justification for this, giving the employee a further seven working days to respond and confirm if they accept the sanction. If the employee does not wish to accept the sanction or does not respond (without a valid reason) within seven working days, the case will progress to a disciplinary hearing, and confirming the right of appeal.

This option should be outlined to the employee at the point the employee is informed that the case is to progress to a disciplinary hearing, however any such request must be the choice of the employee, without undue pressure from other parties.

The request will be referred to an appropriate manager for consideration who will be supported by a human resource Representative. In considering such a request, the following will be taken into account:

• that a fair and reasonable investigation has taken place
• that responsibility for the misconduct as alleged has been accepted by the employee
• that there is sufficient understanding by the employee that the misconduct is unlikely to be repeated
• that the level of sanction to be issued is fair and consistent
• that the manager has authority, or delegated authority, to apply the level of sanction to be issued

In addition, the manager may deem it appropriate to direct the employee to undertake learning or measures to improve future conduct for ongoing employment with the trust.

Sanctions without a formal hearing can be issued for an improvement notice, a first written warning and final written warning

A request for a warning without a formal hearing will not normally be accepted in cases of alleged gross misconduct and where dismissal is being considered as a potential outcome.

If the manager does not believe a warning without a formal hearing is appropriate to be issued, the case will proceed to a formal disciplinary hearing.

7 Disciplinary sanctions

Disciplinary sanctions are intended to provide an employee with the opportunity and impetus to improve their behaviour, as well as making them aware of the consequences of failing to do so. It may, however, sometimes be necessary, according to the severity of the alleged misconduct, to move towards a final written warning or dismissal where a lesser sanction would be considered inappropriate.  For example, where the misconduct has been such that repetition could not be tolerated, a final written warning would be appropriate.

Except for gross misconduct (as defined in the disciplinary toolkit) no employee will be dismissed for a first breach of discipline.

Disciplinary sanctions can only be issued by a manager with the delegated authority to do so, as set out at appendix A.  If the manager hearing the case feels that the alleged misconduct, if proven, will merit a sanction at a higher level than they are authorised to issue, in accordance with the schedule of delegation they should adjourn the hearing, and arrange for the case to be reheard at a later date by a more senior manager.

The potential outcomes of a formal disciplinary hearing include no action, or one of the sanctions set out below. If an employee is already subject to an improvement notice or warning, the outcome could be an extension of the existing sanction. Should an employee have accepted responsibility for issues of a similar nature under the personal responsibility framework as detailed in section 5.2 consideration may be given to the appropriate level of sanction under this policy based on previous acknowledgement of those issues.

For those employees subject to a live disciplinary sanction being issued, incremental pay-step progression will be deferred.

7.1 Improvement notice

If an allegation of misconduct which is not serious in nature is upheld, an improvement notice would normally be issued, setting out the nature of the misconduct and the change in behaviour required

The improvement notice will remain active for 6 months from the date of the hearing (although if the employee is absent from work for a period of over four weeks during this period, the Improvement Notice will be extended to reflect the period of absence), and will be disregarded for disciplinary purposes after this time. However, a record of the improvement notice will remain on the employee’s personal file indefinitely.

The employee will be informed that the consequence of failure to change the behaviour that has led to the issue of an improvement notice will result in a further investigation and possible disciplinary action, which could then result in a more serious sanction.

7.2 First written warning

Where there is a failure to respond to an improvement notice, or where the alleged misconduct is sufficiently serious, and the allegation is upheld, the employee may be issued with a first written warning, setting out the nature of the misconduct and the change in behaviour required.

The first written warning will remain active for 6 months from the date of the hearing (although if the employee is absent from work for a period of over four weeks during this period, the first written warning will be extended to reflect the period of absence), and will be disregarded for disciplinary purposes after this time. However, a record of the first written warning will remain on the employee’s personal file indefinitely.

The employee will be informed that the consequence of failure to change the behaviour that has led to the issue of a first written warning will be further disciplinary action, which could result in a more serious sanction.

7.3 Final written warning

In cases where an employee has failed to respond to lesser disciplinary sanctions, or where the alleged misconduct is very serious and the allegation(s) is or are upheld, the employee may be issued with a Final written warning, setting out the nature of the misconduct and the change in behaviour required.

The final written warning will remain active for 12 months (or longer in exceptional circumstances) from the date of the hearing (although if the employee is absent from work for a period of over four weeks during this period, the final written warning will be extended to reflect the period of absence), and will be disregarded for disciplinary purposes after this time. However, a record of the final written warning will remain on the employee’s personal file indefinitely.

The employee will be informed that the consequence of failure to change the behaviour that has led to the issue of a final written warning will be further disciplinary action, which depending on the circumstances, could result in their dismissal.

7.4 Dismissal

Where there is a failure to respond to a lesser disciplinary sanction, or where an allegation of gross misconduct is upheld, the employee may be dismissed. In cases where the dismissal relates to a failure to respond to a lessor disciplinary sanction the employee will receive pay in lieu of notice. The pay in lieu of notice will be paid at the next available pay date, which may be the month of the dismissal or the following month if the payroll has already been processed for that month. A payment in lieu of notice is calculated on basic or contractual pay only.

In cases of gross misconduct, dismissal will be ‘summary’, for example, the employee will not be entitled to receive notice or pay in lieu of such notice. In other circumstances, for example, issues dealt with under the management of performance (capability) policy and procedure and the policy relating to the management of sickness absence dismissal will be with full pay and notice.

7.5 Disciplinary letters

Whilst an employee will generally be informed of the outcome of a disciplinary hearing at the conclusion of the hearing, it must also be confirmed in writing, usually within seven working days of the hearing.

Other relevant parties will be informed of the outcome of any disciplinary where appropriate?

Consideration must be given to the requirement of the Information sharing with external organisations’ policy (section 13).

The letter should set out the allegations against the employee, and whether they were upheld, as well as giving a summary of the reasons for the decision.  It should also give details of any formal sanction issued, including its duration, the behaviour that led to its issue and the consequences of failure to change such behaviour (provided that the employee has not been dismissed). The letter should give details of how to appeal against any formal disciplinary sanction.

It is the responsibility of the chair of the panel to ensure that this letter is sent.

7.6 Gross misconduct

Gross misconduct is an act or series of acts which result in a serious breach of contractual terms (either implied or explicit), including a breach of the implied term of trust and confidence between employees and their employer. A list of examples of gross misconduct can be found in the disciplinary toolkit.

7.7 Criminal action

The trust reserves the right to take disciplinary action when events or allegations are the subject of a police or counter fraud investigation or criminal proceedings relating to alleged conduct or incidents outside the workplace. For medical and dental employees further consideration should be given to maintaining high professional standards (opens in new window).

Criminal conduct or alleged criminal conduct outside employment may lead to dismissal in certain circumstances. The main consideration will be whether the situation is one that makes the employee unsuitable for their work or unable to fulfil the obligations of the contract of employment in a satisfactory manner.

Misconduct outside the trust where it has a direct bearing on the trust’s operation or reputation may also render an employee liable to disciplinary action including dismissal.

Where the trust suspects that an employee has committed a criminal act (for example, fraud or abuse of patients) it reserves the right to refer the matter to the police or the local counter fraud specialist (LCFS) as appropriate.

8 Right of appeal

In cases where an Improvement notice, first written warning or final written warning has been issued, employees have the right to appeal against the decision to a manager one level above the manager who made the original decision.

Employees who have been dismissed have the right to appeal against the dismissal to representatives of the board of directors.

Employees will be advised at disciplinary hearings and in the letter confirming the outcome of any disciplinary hearing of their right of appeal and will be given details of to whom any appeal should be addressed.

Appeals must be lodged in writing by the employee or their Staff

Side or professional organisation representative within 21calendar days of the date of the letter confirming the disciplinary sanction, and the case for the appeal must be outlined in full.

Appeal hearings will be a review of the original decision, based on the case submitted by the employee and management’s response. Appeal panels will not contain anyone who has had previous involvement with the case. Appeal panels will be advised by a member of the human resources department.

The letter will also remind the employee of their right to be accompanied by a companion who is not otherwise involved in the process. The definition of a companion is detailed in section 5.6.

The purpose of the hearing will normally be to establish whether the conclusions of the original disciplinary hearing were correct and whether the disciplinary sanction imposed at that hearing should be upheld, overturned, or replaced with a lesser sanction. Where the sanction is overturned, consideration needs to be given to the implications on any deferred pay-step progression in line with the pay progression procedure.

Where an appeal is to representatives of the board of directors, the panel will consist of three members of the board of directors and will be chaired by a director.  Where the panel has fully re-heard the case and decides that the original sanction was inappropriate, the director on the panel will decide what, if any, alternative sanction to issue after taking into account the views of the  other panel members and the advice of the human resources representative. Where the appeal panel has not heard all of the evidence that was presented to the original disciplinary panel, but feels that the original outcome was unreasonable, they can remit the case to a fresh disciplinary panel for a full re-hearing.

Should the appeal panel believe further information is required appropriate adjournment(s) to obtain the information should be taken.

Appeals will always be dealt with as soon as possible and will if possible be heard ideally within six weeks of an appeal being lodged.

9 Referrals

9.1 Referral to the disclosure and barring service

Where an employee is dismissed, or resigns from their position, following allegations that they have harmed or placed at risk of a harm a child or adult, whether deliberately or negligently, the trust has a legal duty to refer the case to the disclosure and barring service (DBS). The DBS will review the case and decide whether it is necessary to place the individual’s name on either the children’s or adults’ barred list, thus preventing them from working in a regulated position with the group in question.

9.2 Referral to professional bodies

In cases where disciplinary action is taken against an employee regarding the allegations that may constitute a breach of the code of practice of the relevant professional body, the trust may refer the case to the employee’s professional body.

Consideration should be given in respect of whether an immediate referral should be made at the investigation stage. This would apply where the allegations are serious in nature and, or the employee resigns from the trust.

Any decision to instigate a referral for nursing employees would be made by the director of nursing and allied health professionals and they should be contacted for advice in respect of this matter.  A decision to instigate a referral for medical employees would be made by the medical director and they should be contacted for advice in respect of this matter.

Where the professional body then suspends, removes or places conditions on an employee’s professional registration, the trust may need to take further disciplinary action.

10 Training implications

The following employees will need to be familiar with its contents:

• board of directors
• managers
• employees
• staff side or professional organisation representatives

Training will be provided for new investigating officers which will include regular refresher training.

11 Monitoring arrangements

11.1 Number of formal disciplinary cases

• How: Completion of monitoring data by HR staff.
• Who: Head of employee relations.
• Reported to: People and organisational development committee.
• Frequency: Annual.

11.2 Ethnicity, gender, staff group, grade, timescales, care group of employees subject to formal disciplinary action

• How: Completion of monitoring forms by HR employees.
• Who: Head of employee relations.
• Reported to: People and organisational development committee.
• Frequency: Annual.

12 Equality impact assessment screening

To access the equality impact assessment for this policy, please see the overarching equality impact assessment.

12.1 Privacy, dignity and respect

The NHS Constitution states that all patients should feel that their privacy and dignity are respected while they are in hospital. High Quality Care for All (2008), Lord Darzi’s review of the NHS, identifies the need to organise care around the individual, ‘not just clinically but in terms of dignity and respect’.

As a consequence the trust is required to articulate its intent to deliver care with privacy and dignity that treats all service users with respect. Therefore, all procedural documents will be considered, if relevant, to reflect the requirement to treat everyone with privacy, dignity and respect, (when appropriate this should also include how same sex accommodation is provided).

12.1.1 How this will be met

No issues have been identified in relation to this policy.

12.2 Mental Capacity Act 2005

Central to any aspect of care delivered to adults and young people aged 16 years or over will be the consideration of the individuals’ capacity to participate in the decision-making process. Consequently, no intervention should be carried out without either the individual’s informed consent, or the powers included in a legal framework, or by order of the court.

Therefore, the trust is required to make sure that all staff working with individuals who use our service are familiar with the provisions within the Mental Capacity Act (2005). For this reason all procedural documents will be considered, if relevant to reflect the provisions of the Mental Capacity Act (2005) to ensure that the rights of individual are protected and they are supported to make their own decisions where possible and that any decisions made on their behalf when they lack capacity are made in their best interests and least restrictive of their rights and freedoms.

12.2.1 How this will be met

All individuals involved in the implementation of this policy should do so in accordance with the guiding principles of the Mental Capacity Act (2005) (section 1).

13 Links to any associated documents

• ACAS Conducting Workplace Investigations (opens in new window)
• Bullying and harassment policy
• Dealing with bullying and workplace conflict: Guide for managers (opens in new window)
• Counter fraud, bribery and corruption policy
• Social media employee usage policy
• Freedom of information and environmental information regulations policy
• Grievance and dispute policy
• Pay progression procedure
• Personal Responsibility Framework SOP
• Relationships at Work Policy
• Safeguarding adults policy
• Safeguarding children policy
• Sickness absence policy
• Supporting employees with drug and alcohol related problems policy

14 References

• Advisory, Conciliation and Arbitration Service. (2015). Code of Practice on Disciplinary and Grievance Procedures. (opens in new window).
• Department of Health.  (2005).  Maintaining High Professional Standards in The Modern NHS.
• The Transfer of Undertakings (Protection of Employment) Regulations 2006 (as amended by the Collective Redundancies and Transfer of Undertakings (Protection of Employment) (Amendment) Regulations 2014.

15 Appendices

15.1 Appendix A Schedule of delegated authority to deal with disciplinary matters

Authority to deal with disciplinary matters is delegated in accordance with the following schedule.

As a general rule, no manager may dismiss an immediate subordinate. Such a decision will be taken by a higher level of management (for example, normally by a manager on a level higher than the immediate supervisor or manager).

In the event that the manager identified on the schedule is not able to handle a particular disciplinary matter, the hearing may be conducted by the next most senior manager in the care group or corporate hierarchy, or by an equivalent manager from another directorate.

In serious disciplinary matters where the director is not available due to long term absence, the chief executive will determine whether the matter be:

• dealt with by an ‘acting’ manager with delegated authority to dismiss
• dealt with by an alternative director
• handled by the chief executive

Where professional matters are to be addressed under this procedure, consideration needs to be given to whether the scheme of delegation facilitates appropriate professional advice being available to the disciplining officer. Where such advice is required the appropriate professional advisor should be contacted.

Where changes in the organisational structure take place, a facility will exist for staff side and management to agree interim revisions to the scheme of delegation pending publication of a revised schedule.

Category of staff, chief executive:

• improvement notice, chairman
• first written warning, chairman
• final written warning, board of directors
• dismissal, Board of directors

Category of staff, director:

• improvement notice, chief executive
• first written warning, chief executive
• final written warning, board of directors
• dismissal, board of directors

Category of staff, deputy direct or head of department:

• improvement notice, director
• first written warning, director
• final written warning, director
• dismissal, chief executive

Category of staff, care group director:

• improvement notice, director
• first written warning, director
• final written warning, director
• dismissal, chief executive

Category of staff, corporate head of service:

• improvement notice, director
• first written warning, director
• final written warning, director
• dismissal, chief executive

Category of staff, modern matron or service manager:

• improvement notice, corporate head of service, care group nurse director and care group medical director.
• first written warning, corporate head of service, care group nurse director and care group medical director.
• final written warning, corporate head of service, care group nurse director and care group medical director.
• dismissal, director

Category of staff, chief pharmacist or lead psychologist:

• improvement notice, director
• first Written warning, director
• final Written warning, director
• dismissal, chief executive

Category of staff, medical staff, consultants:

• improvement notice, director
• first Written warning, director
• final Written warning, director
• dismissal, chief executive

Category of staff, medical staff, non consultant grades:

• improvement notice, service manager, director, medical director, care group nurse director and care group medical director
• first written warning, service manager, corporate head of service, director, medical director, care group nurse director and care group medical director
• final written warning, service manager, corporate head of service, director, medical director, care group nurse director, care group medical director
• dismissal, director or medical director

Category of staff, all other staff:

• Improvement notice, line manager (band 6 and above)
• first written warning, line manager (band 6 and above)
• final written warning, modern matron or service manager or departmental manager (band 8a or above)
• dismissal, director, corporate head of service, care group director, care group nurse director, care group medical director, deputy care group director, deputy director, head of department

Deputy directors, head of department terminology relates to corporate directorates where there is not a deputy director in the organisational structure, then the most senior manager who reports to the director, known as a corporate head of service or deputy care group director will chair the hearing, as well as the head of all age services and head of specialist services within the Doncaster care group.

15.2 Appendix B Writing a statement, guidance for employees

This guidance also applies to students, volunteers and secondees working within the trust.

The trust has a responsibility to follow up any concerns raised about the conduct or performance of individual employees, teams or services.  If requesting a statement from an employee, managers should issue this guidance at the time of making the request.

15.2.1 Statements

If you have raised concerns or allegations, have witnessed incidents of concern, or have had allegations made about you, you may be asked to provide a written statement about what happened.

You may be provided with appropriate help in completing a written statement if you need it, for example if you have a disability or English is not your first language. However, it is important that the statement is written in your own words and is not influenced by the views or recollections of others.

Before writing a statement:

• be clear about why you have been asked to write it. If you are unsure, ask
• you can contact your trade union or professional organisation for advice
• be aware that your statement may be used for the purposes of an investigation and you therefore may be asked to attend an investigatory interview to discuss it further. If the allegations are serious, you may also be asked to attend a disciplinary hearing as a witness at a later date

When writing your statement:

• it should be typed if possible and if not, the writing should be clearly legible
• record what you saw or heard or noticed or the venue or layout. This should be based on facts that you personally witnessed
• wherever possible include the date and time of the incident(s)
• if you don’t remember details, record this on your statement. Don’t guess
• record names of other people who were present at the time the incident(s) occurred (give their full name and position, if known)
• do not use abbreviations
• take your time to write your statement and be aware it can be used as evidence in formal hearings or processes so it is important that it is correct before submitting it
• ensure that your name and job title are included and that you have signed and dated it

You should also keep your own copy of your statement and bring it with you to any investigation meeting or hearing you are subsequently asked to attend.

15.2.2 Trade union or professional organisation representation

If you are asked to write a statement for the purposes of a disciplinary investigation, you are entitled to seek advice from your trade union or professional organisation representative prior to submitting it.

If you are not a member of a trade union or professional organisation you can seek advice from your line manager, the investigating officer or a human resources representative.

15.2.3 Investigation Interviews

In the course of conducting a disciplinary investigation, the investigating officer may ask to meet with you to ask some further questions about what you have witnessed. If so, you will be given notice of the meeting in writing, which may include email and you may be accompanied by a trade union or professional organisation representative or work colleague who is not otherwise implicated or involved in the investigation. A representative from the HR department may also be present at the meeting. In some cases there may also be an additional note taker present.

Notes will be taken at the meeting and you will be asked to check these afterwards and sign a copy to confirm that you agree that it is an accurate record. You will have the opportunity to request that amendments are made if you believe there to be any inaccuracies or omissions in the notes taken.

15.2.4 Disciplinary hearings

If the concern is of a serious nature and there is sufficient evidence, the case may be referred to a disciplinary hearing. If you have provided a statement or attended an investigation meeting, you may also be asked to attend the disciplinary hearing as a witness, in which case you can be accompanied by a trade union or professional organisation representative or a work colleague (as long as they are not otherwise implicated or involved in the case).

You may also be given the name of a HR advisor who will be available for you to contact with any questions about what to expect when attending a disciplinary hearing. If you wish to speak to someone in the human resources department please call 03000 213 000 and ask to speak to a HR advisor.

To maintain the confidentiality of all parties, you should not discuss the investigation or disciplinary hearing with anyone other than the investigating officer, line manager, a HR advisor or your trade union or professional organisation representative.

We recognise that this may be a very difficult and anxious time for everyone and all employees are reminded that they can access the employee assistance programme (opens in new window) (EAP) VIVUP on 03303 800 658. This support is available 24 hours a day 7 days a week.

15.3 Appendix C Disciplinary hearing process

Name:

[Member of staff who is the subject of hearing]

Date of hearing:

[Date and time]

Location:

[Room or building or site]

Panel chair:

[Name or job title]

HR representative to the panel:

[Name or job title]

Other panel members:

[Name or job title]

[For example, specialist professional or clinician]

Presenting officers:

[Name(s) or job title(s)]

[For example, investigating officer or investigating HR representative]

Hearing attendees:

[Name(s) or job title(s) or role in hearing]

[For example, witness or companion (if applicable) or note taker etc.]

A HR representative may accompany the investigating officer to the hearing if they have carried out the investigation jointly and the investigating officer is inexperienced in this area of work and or the matters under investigation are complex in nature. Responsibility for managing a fair and reasonable process rests with the chair.

15.3.1 Procedure

1. Panel chair, accompanied by a HR representative and any other panel members, opens meeting by inviting the employee and their companion (as applicable) into the room.
2. Panel chair introduces the panel, explains the panel members’ roles in the hearing and invites the employee and their companion (as applicable) to introduce themselves to the panel.
3. Panel chair explains the planned format of the hearing and the procedure to be followed in conducting the hearing (as set out in this document).
4. Panel chair asks employee to confirm if they received and understood the disciplinary pack of documents that was sent, including the invitation to the hearing, the allegations made, a copy of the investigatory report and any appendices, and a copy of the applicable disciplinary policy and procedure.
5. Panel chair clarifies the details of the witnesses which the employee has confirmed that they will be calling to the hearing and confirms the names of any witnesses who have been invited to attend by the investigating officer or panel.
6. Employee is invited by the panel chair to ask any questions of the panel as appropriate throughout the hearing and states that an adjournment can be requested at any time. Panel chair explains that employee or their companion will be advised as to when they can ask questions of any witnesses attending the hearing.
7. Employee (or their companion, as preferred) is invited by the panel chair to make a short opening statement confirming or refuting the allegations, before any other hearing attendees are invited into the room, and to provide any additional or new information, that may not have been considered during the investigation, at this stage. (Any new or additional information must be shared with the investigating officer or HR representative at the point they join the hearing)
8. Panel chair invites the investigating officer (and an accompanying representative, if applicable) into the room to present the case. The panel chair will clarify whether any new or additional information has been shared and confirm the witnesses attending.
9. Investigating officer presents the findings of the investigation, by summarising the key findings.
10. Panel chair and other panel members ask any questions they have of the investigating officer (and or the accompanying HR representative, if applicable).
11. Employee (or their companion, as preferred) asks any questions they have of the investigating officer (and or the accompanying representative, if applicable).
12. Panel chair and other panel members ask any further questions they have of the investigating officer (and or the accompanying HR representative, if applicable).
13. Panel chair invites the first management Witness into the room (with their companion if applicable), as determined by the prearranged schedule of witnesses invited to attend.
14. Panel members ask any questions of the witness as required.
15. Employee (or their companion, as preferred) asks any questions of the witness as required.
16. Panel members ask any further questions of the witness as required.
17. Panel chair invites the investigating officer or HR representative to provide any clarifying information where previously unaddressed matters have been raised by the witness or whether they have any questions to raise directly with the witness or the employee subject to the hearing.
18. Panel chair, with the agreement of the employee (or their companion, as preferred) checks that no further questions will be asked, advises witness that they can leave the hearing and if they are likely to be recalled.
19. Panel members may ask any further questions of the employee (or their companion, as preferred) whilst witnesses are present in the room, if appropriate, or in the period of time between witnesses being called into the room, as required.
20. Any further management witnesses invited to attend the hearing are called into the room, one by one, as per points 13 to 19 (above). Each witness is invited in separately and must leave the room before the next witness is called, unless there are exceptional circumstances and there is prior agreement by all parties for more than one witness to attend the hearing at the same time.
21. Employee witnesses are invited to attend the hearing one by one, as per points 13 to 20 (above).
22. Investigating officer (and or their accompanying representative, if applicable) is invited to offer a closing statement.
23. Panel chair invites employee (or their representative, as preferred) to offer a closing statement prior to the panel members considering their decision.
24. Panel chair calls an adjournment to the hearing for the panel members to consider their decision with regard to a disciplinary outcome. Panel chair advises employee (and their companion, if applicable) how long adjournment is expected to last and requests confirmation of the best way to contact the employee during the adjournment, should they need to be recalled earlier or later than expected. The investigating officer and the HR representative are advised that they will not be recalled for the outcome but may be recalled should further clarification become appropriate.
25. If the panel considers that they need further information, or there is information missing, they should require that the information is provided to them, either after a short adjournment to allow parties to obtain documents or call witnesses to attend, or, to adjourn and reconvene on another date if necessary, for example, if further investigations are required. The reasons for any decision made by the panel should be fully documented.
26. Hearing is reconvened with panel members and employee (and their companion, if applicable) present.
27. Outcome of the hearing is communicated by the panel chair, with a clear explanation of why the decision has been reached and whether there are any specific actions arising from the outcome, for example, remedial actions such as a formal action plan or training requirements
28. Appeal process is explained by the chair of the panel or HR Representative to the panel and confirmation given that a letter will follow to summarise the hearing and fully explain the outcome of the disciplinary process.
29. Any relevant practicalities arising from the outcome will be explained by the chair of the panel or the HR representative to the panel, as appropriate, for example, the return of trust property where the outcome is dismissal from the trust.
30. Panel chair brings the hearing to a close.
31. The panel chair is responsible for ensuring that any learning points or recommendations arising from the hearing are formally recorded, and subsequent actions implemented in the trust and or relevant care group or department or teams.

---

Document control

• Version: 9.2.
• Unique reference number: 236.
• Ratified by: People and teams CLE group.
• Date ratified: 11 June 2024.
• Name of originator or author: Head of human resources
• Name of responsible individual: Director of people and organisational development.
• Date issued: 3 July 2024.
• Review date: 30 November 2024 (Extension).
• Target audience: All Staff.

Page last reviewed: October 22, 2024
Next review due: October 22, 2025

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