Ex-Offenders Policy

Company name: Petchey Car Hire Ltd
Registered address: Station Garage, 186 High Street North, East Ham, London, E6 2JA

1. Policy statement

Petchey Car Hire Ltd is committed to promoting equality of opportunity for all applicants and employees and to ensuring that individuals are selected, retained and developed on the basis of their abilities and merits.

The Company recognises that having a criminal record does not necessarily make a person unsuitable for employment. We therefore undertake to treat all applicants fairly and not to discriminate unfairly against any individual on the basis of a criminal conviction or other information revealed through criminal record checks.

This policy applies to all job applicants, employees, agency workers and contractors engaged by Petchey Car Hire Ltd.

2. Purpose

The purpose of this policy is to:

• Ensure compliance with the Rehabilitation of Offenders Act 1974 and related legislation;
• Promote fair treatment of applicants and employees with criminal records;
• Ensure that criminal record information is handled appropriately and confidentially;
• Protect the interests of customers, employees and the business while providing equal employment opportunities.

3. Equality of opportunity

Petchey Car Hire Ltd actively promotes equality of opportunity for all candidates.

Where a criminal record check is required for a role, this will be made clear during the recruitment process. Applicants will be informed if a Disclosure and Barring Service (DBS) check forms part of the recruitment process.

Having a criminal record will not automatically bar an applicant from employment. Any decision will be made on a case-by-case basis, taking into account the nature of the role and the circumstances of the offence.

4. Assessment of criminal records

Where criminal record information is disclosed, the Company will consider:

• The nature and seriousness of the offence;
• The relevance of the offence to the position applied for;
• The length of time that has passed since the offence occurred;
• Whether there is a pattern of offending behaviour;
• The age of the individual at the time of the offence;
• Evidence of rehabilitation and positive conduct since the offence;
• The responsibilities and risks associated with the role.

No applicant will be unfairly excluded solely because they have a criminal record.

5. Rehabilitation of Offenders Act 1974

The Company will comply fully with the Rehabilitation of Offenders Act 1974.

For positions covered by the Act, applicants will not be required to disclose spent convictions and such convictions will not be taken into account when making employment decisions.

Where a role is exempt from the Act and a DBS check is legally required, applicants may be asked to disclose convictions in accordance with the applicable legal requirements.

6. Disclosure and Barring Service (DBS) checks

Where DBS checks are required, Petchey Car Hire Ltd will:

• Only request criminal record information that is relevant and lawful for the role;
• Ensure applicants understand why the information is being requested;
• Assess disclosed information fairly and objectively;
• Comply with the DBS Code of Practice;
• Maintain the confidentiality and security of all information obtained.

A disclosed conviction or caution will not necessarily result in the withdrawal of an offer of employment.

7. Confidentiality and data protection

Information relating to criminal convictions will be handled in strict confidence and in accordance with:

• The UK General Data Protection Regulation (UK GDPR);
• The Data Protection Act 2018; and
• Any other applicable legal requirements.

Access to criminal record information will be restricted to those individuals who require the information as part of their duties.

Information will be retained only for as long as necessary and will be securely destroyed when no longer required.

8. Existing employees

Employees are expected to notify the Company if they are convicted of a criminal offence during their employment where:

• The conviction may affect their ability to perform their role;
• The conviction may affect any licence, permit or certification required for their employment;
• There is a legal, contractual or regulatory requirement to disclose such information.

Any disclosure will be considered fairly, confidentially and on an individual basis.

9. Training and responsibility

Managers involved in recruitment and employment decisions are responsible for ensuring that this policy is applied consistently and fairly.

Appropriate guidance and training will be provided where necessary to ensure compliance with legal obligations and best practice.

10. Monitoring and review

Petchey Car Hire Ltd will review this policy periodically to ensure that it remains compliant with current legislation and reflects best practice in recruitment and employment.

Approval

This policy has been approved by Petchey Car Hire Ltd.

Effective date: 1 October 2026
Review date: 1 October 2027
Signed: Anjum Chowdhery
Position: Group General Manager

For and on behalf of Petchey Car Hire Ltd.