Our Policies



Virginia Cinquemani, Director, is responsible for ensuring that the all Green Gorilla’s policies are implemented. However, all employees and contractors acting on behalf of Green Gorilla have a responsibility in their area to ensure that the aims and objectives of the policies are met.

Policies Review Arrangements

All employees and contractors will be made aware of all Green Gorilla’s Policies and keep the policies regularly updated and communicated so no employee or contractor can use the excuse of ignorance.

It is important that all staff involved in the management, assessment and quality assurance of our courses and services, and learners, are fully aware of the contents of the policies.

Green Gorilla will review all the policies at least annually as part of our self-evaluation arrangements and revise them as and when necessary in response to customer and learner feedback or requests from, or good practice guidance issued by, the regulatory authorities. If you would like to feedback any views please send your comments to This email address is being protected from spambots. You need JavaScript enabled to view it.

Environmental Policy

Mission statement

Green Gorilla Consultants Ltd (“Green Gorilla”) recognises that it has a responsibility to the environment beyond legal and regulatory requirements. We are committed to reducing our environmental impact and continually improving our environmental performance as an integral part of our business strategy and operating methods, with regular review points. We will encourage customers, suppliers and other stakeholders to do the same.

Policy aims

We endeavour to:

  • Comply with and exceed all relevant regulatory requirements.

  • Continually improve and monitor environmental performance.

  • Continually improve and reduce environmental impacts.

  • Incorporate environmental factors into business decisions.

  • Increase employee and contractor awareness and training.


  • We will minimise the use of paper in the office.

  • We will reduce packaging as much as possible.

  • We will seek to buy recycled and recyclable paper products.

  • We will reuse and recycle all paper where possible.

Energy and water

  • We will seek to reduce the amount of energy used as much as possible.

  • Lights and electrical equipment will be switched off when not in use.

  • Heating will be adjusted with energy consumption in mind.

  • The energy consumption and efficiency of new products will be taken into account when purchasing.

Office supplies

  • We will evaluate if the need can be met in another way.

  • We will evaluate if renting/sharing is an option before purchasing equipment.

  • We will evaluate the environmental impact of any new products we intend to purchase.

  • We will favour more environmentally friendly and efficient products wherever possible.

  • We will evaluate the ethical labour impact of our purchases.

  • We will reuse and recycle everything we are able to.



  • We will reduce the need to travel, restricting to necessity trips only.

  • Our courses will mainly be delivered online to reduce the impact of travel.

  • We will promote the use of travel alternatives such as e-mail or video/phone conferencing.

  • When travelling on business, we will use public transport as much as possible.

  • We will make additional efforts to accommodate the needs of those using public transport or bicycles.

  • We will favour ‘green’ vehicles and maintain them rigorously to ensure ongoing efficiency.

Maintenance and cleaning

  • Cleaning materials used will be as environmentally friendly as possible.

  • Materials used in office refurbishment will be as environmentally friendly as possible.

  • We will only use licensed and appropriate organisations to dispose of waste.

Monitoring and improvement

  • We will comply with and exceed all relevant regulatory requirements.

  • We will continually improve and monitor environmental performance.

  • We will continually improve and reduce environmental impacts.

  • We will incorporate environmental factors into business decisions.

  • We will increase employee and contractor awareness through training.

  • We will review this policy and any related business issues at our monthly management meetings.


  • We will involve staff in the implementation of this policy, for greater commitment and improved performance.

  • We will update this policy at least once annually in consultation with staff and other stakeholders where necessary.

  • We will provide staff and contractors with relevant environmental training.

  • We will work with suppliers, contractors and sub-contractors to improve their environmental performance.

  • We will use local labour and materials where available to reduce CO2 and support the local community.

Health and Safety Policy

  • Prevent accidents and cases of work-related ill health by managing the health and safety risks in the workplace.

  • Provide clear instructions and information, and adequate training, to ensure employees and contractors are competent to do their work.

  • Engage and consult with employees and contractors on day-to-day health and safety conditions.

  • Implement emergency procedures – evacuation in case of fire or other significant incident.

  • Maintain safe and healthy working conditions, provide and maintain plant, equipment and machinery.

Equal Opportunities Policy

Green Gorilla is committed to equal opportunities and non-discriminatory procedures and practices.

The Equality Act 2010 covers nine protected characteristics, making it unlawful to discriminate on the grounds of:

  • Age

  • Disability (those who have, or have had, a disability)

  • Gender Reassignment (no longer required to be under medical supervision)

  • Marriage and Civil Partnership

  • Pregnancy and Maternity

  • Race

  • Religion or Belief (including lack of belief)

  • Gender

  • Sexual Orientation

We are committed to supporting learners to work and study in an environment that is free from unlawful discrimination and promotes equality of opportunity and good relations between people of different racial groups.

We are working towards a culture that welcomes equality of opportunity and values diversity.

All employees and contractors are expected to respect and act in accordance with the policy and any bullying or harassment in the workplace is totally unacceptable and subject to prompt action.

Equality of opportunity exists for all job applicants, prospective employees and current workers.

Any grievance and complaint on the basis of discriminatory acts, bullying or harassment will be taken seriously into consideration and investigated promptly by the Director, and adequate actions will be taken to ensure such instances do not occur.

Safeguarding Policy

The Safeguarding policy relates to the safeguarding of vulnerable adults. Vulnerable adults are defined as:

  • People aged 18 or over

  • “Who are receiving or may need community care services because of learning, physical or mental disability, age, or illness, who are or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation.” (Department of Health, 2000)

Green Gorilla is strongly committed to practices that protect vulnerable adults from abuse, neglect, significant harm, stop becoming, drawn into, promoting or supporting terrorism. Staff recognise and accept their responsibility to develop the awareness of the risks and issues involved in safeguarding.

The company also recognises that it has a responsibility to protect staff from unfounded allegations of abuse. The company is committed to working with existing local safeguarding or adult safeguarding Boards and other health and social care partnerships to ensure the safeguarding of its learners whilst recognising the 19 definitions of potential abuse.

The policy applies to all staff, contractors and anyone working on behalf of Green Gorilla.

The following principles apply:

  • All adults, regardless of age, ability or disability, gender, race, religion, ethnic origin, sexual orientation, marital or gender status have the right to be protected from abuse and poor practice and to participate to the activities run by Green Gorilla in an enjoyable and safe environment.

  • Green Gorilla will seek to ensure that our courses are inclusive and make reasonable adjustments for any ability, disability or impairment; we will also commit to continuous development, monitoring and review.

  • The rights, dignity and worth of all adults will always be respected.

  • We recognise that ability and disability can change over time, such that some adults may be additionally vulnerable to abuse, in particular those adults with care and support needs

  • We all have a shared responsibility to ensure the safety and well-being of all adults and will act appropriately and report concerns whether these concerns arise, for example inappropriate behaviour of a trainer, or in the wider community. 

  • All allegations will be taken seriously and responded to quickly.

  • Green Gorilla recognises the role and responsibilities of the statutory agencies in safeguarding adults and is committed to complying with the procedures of the Local Safeguarding Adults Boards.

The company has a duty to promote safeguarding issues and measures to staff and contractors and ensure they:

  • Analyse their own practice against established good practice, and assess risk to ensure their practice is likely to protect them from false allegations

  • Recognise their responsibilities and report any concerns about suspected poor practice or possible abuse

  • Are aware of current safeguarding issues and Legislation.

Data Protection Policy

Green Gorilla is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be:

  • processed lawfully, fairly and in a transparent manner in relation to individuals;

  • collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;

  • adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

  • accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;

  • kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and

  • processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”

General provisions

This policy applies to all personal data processed by Green Gorilla.

The Director shall take responsibility for the Green Gorilla’s ongoing compliance with this policy.

The Green Gorilla, as an organisation that handles personal data, shall comply with the information handling duties as per Information Commissioner’s Office guidance.

Lawful, fair and transparent processing

  • To ensure its processing of data is lawful, fair and transparent, Green Gorilla shall maintain a Register of Systems.

  • The Register of Systems shall be reviewed at least annually.

  • Individuals have the right to access their personal data and any such requests made to the charity shall be dealt with in a timely manner.

Lawful purposes

  • All data processed by Green Gorilla must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).

  • Green Gorilla shall note the appropriate lawful basis in the Register of Systems.

  • Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.

  • Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in Green Gorilla’s systems. 

Data minimisation

Green Gorilla shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.


Green Gorilla shall take reasonable steps to ensure personal data is accurate.

Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

Archiving / removal

To ensure that personal data is kept for no longer than necessary, the Green Gorilla shall put in place an archiving policy for each area in which personal data is processed and review this process annually.

The archiving policy shall consider what data should/must be retained, for how long, and why.


Green Gorilla shall ensure that personal data is stored securely using modern software that is kept-up-to-date. 

Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.

When personal data is deleted this should be done safely such that the data is irrecoverable.

Appropriate back-up and disaster recovery solutions shall be in place.


In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, Green Gorilla shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).

Plagiarism Policy

Neville (2007) defines plagiarism as:

"A practice that involves knowingly taking and using another person’s work and claiming it, directly or indirectly, as your own."

This definition is very wide and covers a range of degrees of seriousness and intention. Learners may plagiarise the work of others on purpose to obtain a qualification unfairly. Alternatively, learners may plagiarise unintentionally out of not knowing how to record research from websites and text books. Whether it is intentional or not, plagiarism presents a problem when it interferes with the accurate assessment of a learner’s knowledge and skills.

Green Gorilla has an obligation to the awarding bodies, the learners, the employers and society in general, to ensure that plagiarism does not allow learners to attain qualifications that do not accurately represent their own knowledge and skills.

Plagiarism undermines the value of qualifications for all concerned. If a learner achieves a qualification by unfair means, then this is also unfair to all other learners who achieve the same qualification fairly.

Plagiarism may also be seen as a breach of trust between staff and learners, and between individual learners. Furthermore, it may suggest a disregard for values such as honesty and fairness, which may affect relationships between employers and learners.

For these reasons, Green Gorilla will take all appropriate measures to ensure that learners’ submitted work is their own, and that plagiarism and other forms of cheating have not taken place.

It is the responsibility of all learners and staff to ensure that learners’ submitted work, especially for the purposes of summative assessment, is their own work.

Green Gorilla will take appropriate action where plagiarism is detected. This may result in disciplinary action and removal from the programme.

Green Gorilla will:

  • Train staff in plagiarism prevention and detection

  • Inform learners of our position on plagiarism

  • Promote an ethos of fairness and appropriate reward for effort

  • Ensure that learners are taught how to record research and reference work appropriately

  • Take disciplinary action as appropriate.

Learners are expected to:

  • Advise staff of any issues which may impact on their ability to complete their work.

  • Refrain from plagiarism.

Impact measures and monitoring

  • Annual review of data on incidents of plagiarism and subsequent outcomes.

  • Observation of teaching and learning, staff and learner feedback, and staff training.

Reasonable Adjustment Policy

A reasonable adjustment is any action that helps to reduce the effect of a disability or difficulty that places the learner at a substantial disadvantage in the assessment situation. It is made to an assessment for a qualification to enable a disadvantaged learner to demonstrate his or her knowledge, skills and understanding of the levels of attainment required by the specification for that qualification.

Reasonable adjustments must not affect the integrity of what needs to be assessed, but may involve:

  • changing usual assessment arrangements, for example allowing a learner extra time to complete the assessment activity

  • adapting assessment materials, such as providing materials in Braille

  • providing assistance during assessment, such as a sign language interpreter or a reader

  • re-organising the assessment room, such as removing visual stimuli for an autistic learner

  • changing the assessment method, for example from a written assessment to a spoken assessment

  • using assistive technology, such as screen reading or voice activated software

  • providing the mechanism to have different colour backgrounds to screens for onscreen assessments or asking for permission for copying to different coloured paper for paper-based assessments

  • providing and allowing different coloured transparencies with which to view assessment papers.

Reasonable adjustments are approved or set in place before the assessment activity takes place; they constitute an arrangement to give the learner access to the programme. The use of a reasonable adjustment will not be taken into consideration during the assessment of a learner’s work.

Green Gorilla are only required by law to do what is ‘reasonable’ in terms of giving access. What is reasonable will depend on the individual circumstances, cost implications and the practicality and effectiveness of the adjustment. Other factors, such as the need to maintain competence standards and health and safety, will also be taken into consideration.

Special Consideration Policy

Special consideration is action taken after an examination to allow candidates who may have been disadvantaged by temporary illness, injury, indisposition or adverse circumstances at the time of the examination to have their performance reviewed in the light of the circumstances in question.

A candidate may apply for special consideration if:

  • performance in an external assessment is affected by circumstances beyond the control of the candidate, e.g. personal illness, temporary injury or bereavement.

  • alternative assessment arrangements agreed in advance proved inappropriate or inadequate

  • disruption to the examination (undue noise levels in or near the examination room, fire alarm, music etc.)

If an application for special consideration is approved, then the trainer will be informed at the time of marking the assessment. Examination results will be moderated to ensure that markers are assessing consistently at the right level. A chief moderator will also consider candidate results on a case by case basis and adjust them accordingly. Any special consideration applied will not remove the difficulty faced at the time of the assessment and can only be an adjustment to ensure the integrity of the assessment is not compromised.

Applications for special consideration should be submitted in writing to Green Gorilla as soon as possible after the event and no later than 21 days after the examination in question. Requests for special consideration will not be considered after the issue of results. The appeals and re-marks procedures will then apply.

The candidate needs to supply documented evidence to support their application. This may include medical evidence or a statement from the examination officer/invigilator or any other appropriate information. The signatory must declare the information given is accurate.

Complaints and Malpractice Policy

All appeals and complaints should be made in writing to Green Gorilla Consultants Ltd, 3 Windsor Court, Park View Close, St Albans, AL1 5TT.

Learners could complain to the centre about the following areas:

  • Information, Advice and Guidance provided by Green Gorilla

  • access to training

  • process of training

  • the handling of an appeal

  • Administrative issues, e.g. failure to register/apply for certification.

Trainers/Coaches could complain to the centre about the following areas:

  • access to support and guidance

  • access to internal verification

  • administrative issues

  • Insufficient time to undertake the function.

The Director will attempt to find a solution with the learner and trainer/coach for example through re-consideration of the evidence/work;

Where this does not resolve the situation, the Director will:

  • set a date for the appeal/complaint to be considered by an appeals panel

  • The appeals panel will meet to consider the appeal within 20 working days of the Director receiving the appeal.

  • the appeals panel will be constituted so as to be objective and independent

  • the panel will ensure that it has full accounts from all parties involved

  • no one involved in the original dispute will be on the panel.

Appeal Policy

Green Gorilla may charge a fee to cover the administrative and personnel costs involved in dealing

with appeals. If the appeal is successful, the fee will be refunded.

This policy covers:

  • appeals from learners in relation to an assessment or training decision on the basis that Green Gorilla did not apply procedures consistently or that procedures were not followed properly and fairly

  • appeals from learners relating to a Green Gorilla’s decision to decline a learner’s request to make reasonable adjustments or give special considerations

  • appeals from learners relating to a decision made by Green Gorilla following an investigation into a complaint.

Learners have 14 days from the date Green Gorilla notified the learner of the decision in which to lodge an appeal against Green Gorilla’s decision - this includes assessment results; hence learners/staff must retain course evidence, where appropriate until results are received.

© Green Gorilla Consultants Ltd. July 2019 Rev.2.0