Corporate Policies

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

This policy sets out the requirements for Data Protection at the ROH, to ensure that all personal information is treated lawfully and correctly, in accordance with the Data Protection Act 2018 and related legislation including the Privacy and Electronic Communications (EC Directive) Regulations 2003. Our privacy policy explains in more detail how we protect the privacy of customer data.

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 Donation and Income Acceptance Committee, is responsible for monitoring compliance with the Board’s policy on accepting funds.

The Donation and Income Acceptance Committee comprises:

  • Chair
  • Senior Independent Director
  • Trustee with legal expertise
  • Trustee Chair of Development Committee
  • 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 2018 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 policy.

Policy on Accepting Sponsorship, Donations and Membership approved by the Board on 29 May 2018 and will be updated in 2021.

Expenses Policy

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.

The Royal Opera House Board of Trustees oversees the direction and control of ROH, including the active management of health and safety. The Board ensures that there is a sufficient budget allocation to put the organisation’s Health and Safety Policy into practice and is committed to encouraging a positive health and safety culture, which is visible throughout the organisation.

Modern Slavery and Human Trafficking Statement

Section 54 of the Modern Slavery Act 2015 requires certain organisation with turnover over £36 million per annum (‘large organisations’) to publish a statement each year outlining the steps it has taken to ensure there is no slavery or human trafficking in its business or supply chain. 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 and is committed to a zero-tolerance approach by continuously improving its practices in relation to every part of its business as well as its supply chain. This statement is made on behalf of The Royal Opera House and its subsidiaries but only the Royal Opera House Covent Garden Foundation is required to make this statement.

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 sixth statement to the published.

As a result of the COVID-19 pandemic, the Royal Opera House closed its doors to the public on 16th March 2020 and moved staff to home working. Since March 2020 repeated lockdowns, social distancing guidance and government regulations have limited our ability to re-occupy the building and return to performing.  Through 2020/2021, we have continued to work remotely, and many staff across the organisation, including those employed by subcontractors, have spent time on furlough. However, we have continued to take steps that to ensure slavery and human trafficking have no place in our supply chain.

Specifically, we have:

  • Continued to adhere to all U.K. government guidance, ensuring that all directly employed staff and freelancers have been protected against the risk of contracting COVID-19
  • Continued to work with our outsourced facilities management contractors to ensure that they, too, take all necessary precautions to protect staff working at the Royal Opera House
  • Paid cancellation fees to artists and musicians scheduled to perform at the Royal Opera House during this time
  • Continued to apply our high standards for staff recruitment and wellbeing, keeping staff informed about their rights in the workplace and avenues for raising concern, and
  • Re-circulated guidance to all staff detailing the signs of potential supplier distress, to monitor the impact of COVID-19 across our supply chain and highlight any areas of concern.

In regards to our supply chain we have:

  • Reviewed and updated the rationale behind out risk assessment methodology for suppliers and updated the process
  • Rolled out a ‘self-service’ due diligence process for low value/low risk sourcing conducted outside the Procurement team
  • Where applicable, included Modern Slavery Act adherence as a minimum standard during tendering processes
  • Further refined our Supplier Code of Conduct to address a wider range of social, economic and sustainability factors, as well as Modern Slavery
  • Begun to embed updated terms & conditions for the supply of goods and services across the organisation
  • Reviewed the format and content of our annual supplier questionnaire and re-issued this to key suppliers in August 2021.

View or download the Modern Slavery and Human Trafficking Statement (PDF, 152 KB)

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 at the Royal Opera House

The ROH Safeguarding approach is in two strands. The first protects children, young people and adults at risk; and the second protects staff and artists (paid or unpaid) from Bullying and Harassment.

Safeguarding Children and Young People (Policy and Procedure)

The ROH Policy for the Protection of Children and Adults at Risk sets out our commitment to protecting the safety and welfare of children and adults who require care and support; to ensuring that our members of staff are kept informed and supported and adhere to effective procedures for recording and responding to complaints and alleged or suspected incidents of abuse. The ROH operates within the City of Westminster safety guidelines for children in stage performances. The HR Director has primary responsibility for Safeguarding within their overall health and safety management responsibilities. They are supported in this role by the Safeguarding Manager. The HR Director chairs the bi-annual Child Protection Committee, which oversees and reviews the policy and procedure.

These are supported by the following procedures and guidelines:

  • Protecting Children in Performance Activities
  • Protecting Children in Non-Performance Activities
  • Photographing Children at the Royal Opera House
  • Responding to Allegations and Concerns
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.

View or download Bullying and harassment policy and procedures (PDF, 155 KB)

Statement of Investment Principles
Whistleblowing Policy and Procedure for Investigation

Hotline: 0808 196 5761

roh.ethicspoint.com

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.

Complaints Policy

This policy sets out the procedure for making a complaint about the ROH including making a complaint about fundraising practice.

View or download Complaints Policy (PDF, 116 KB)