Employment of Ex-Offenders
Company Policy - Candidates based in the UK
Version 2.0. Last updated: 19 August 2025
Purpose
The purpose of this policy is to outline Push Gaming Limited's (the "Company") commitment to fostering equal opportunities for all candidates, including ex-offenders, and to ensure compliance with UK law in the recruitment and employment of individuals with criminal records. This policy aims to create a fair and inclusive recruitment process, promote the successful reintegration of ex-offenders into the workforce, and support their growth and development within the Company. The policy also serves to provide guidance for decision-making personnel on the appropriate handling of disclosure information and adherence to relevant legislation and guidelines. This policy is compliant with the Equality Act 2010, ensuring that individuals with protected characteristics, including those with past convictions, are treated fairly and not subject to unlawful discrimination.
Scope
This policy applies specifically to the UK operations of Push Gaming (the "Company") and is relevant to all candidates applying for employment within the Company's UK-based positions, regardless of the method of submission. The policy is also applicable to all Company personnel involved in the recruitment and decision-making process for UK-based roles.
The scope of this policy covers the Company's adherence to UK law, including the Rehabilitation of Offenders Act 1974, Disclosure and Barring Service (DBS) procedures, and the Data Protection Act 2018. This policy is intended to provide guidance and support for the Company's commitment to fair recruitment practices and equal opportunities for ex-offenders seeking employment within the UK operations of the Company.
It is the responsibility of all decision-making personnel to ensure compliance with this policy and relevant UK legislation. Each member of the Management Team must ensure that their department members are aware of, have read, and understand the content and approach detailed in this policy as it pertains to the UK context.
Disclosure of Convictions
Candidates must disclose any unspent convictions during the application or onboarding process. These convictions may be subject to a balanced and fair discussion regarding their relevance to the job role during an interview.
Candidates are not required to disclose spent convictions or cautions protected under the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 (2013 and 2020). Such convictions will not be considered when determining a candidate's suitability, even if voluntarily disclosed. However, if the position applied for is deemed to require 'utmost integrity,' full disclosure of all convictions and cautions is necessary. Applicants will be informed if the position they applied for is considered to require utmost integrity during the application process. Roles requiring utmost integrity may include those involving substantial financial responsibility, or access to sensitive data or systems.
Failure to declare any unspent convictions before the specified date may result in the withdrawal of an employment offer, disciplinary action, dismissal, or be considered a violation of this policy.
Assessment of Convictions
The Company will assess candidates based on their qualifications, experience, and personal attributes. Criminal records will only be considered if a conviction is deemed relevant or serious enough to warrant further examination of the applicant's suitability. When assessing the relevance of a conviction, factors such as the nature and seriousness of the offence, the time elapsed since the conviction, and the candidate's employment history and rehabilitation efforts will be taken into account.
Fair Treatment and Non-Discrimination
The Company is committed to the fair treatment of its staff and will not unfairly discriminate against any candidate based on a conviction. All recruitment decisions will be made in accordance with UK law and guidelines, ensuring a fair and unbiased assessment of a candidate's suitability for employment.
Confidentiality and Data Protection
All information disclosed regarding a candidate's convictions will be kept confidential and only shared with relevant personnel involved in the decision-making process. The handling, storage, and disposal of disclosure information will be in line with the DBS Code of Practice and the Data Protection Act 2018.
2.0 Compliance with the UK Law
In accordance with UK law, Push Gaming Limited (the "Company") adheres to relevant legislation and guidelines in its approach to employing ex-offenders. This section outlines the Company's policy for the employment of ex-offenders in compliance with UK law.
2.1 Rehabilitation of Offenders Act 1974
The Company abides by the principles of the Rehabilitation of Offenders Act 1974. Under this Act, certain convictions become 'spent' after a specified period of time, known as the 'rehabilitation period.' Once a conviction is spent, the individual is treated as if they have never been convicted, and they are not required to disclose the conviction when applying for most jobs.
2.2 Disclosure and Barring Service (DBS)
When required by law or for specific job roles, the Company will carry out a DBS check to obtain details of an applicant's criminal record. The level of DBS check will depend on the nature of the job role and the applicant's responsibilities. The Company will only request a DBS check if it is legally permissible and relevant to the position.
2.2 Handling of Disclosure Information
The Company will handle, store, and dispose of disclosure information in line with the DBS Code of Practice and the Data Protection Act 2018. Disclosure information will only be shared with relevant personnel involved in the decision-making process and will be kept confidential.
2.3 Support and Development
The Company recognises the importance of providing support and development opportunities for all employees, including ex-offenders. The Company is committed to creating an inclusive workplace culture and offering equal access to training, development, and career advancement for all staff members.
By adhering to UK law and implementing fair recruitment practices, the Company aims to provide equal opportunities for ex-offenders and contribute to their successful reintegration into the workforce.
3.0 Contact Us
You may contact us using the following details:
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Email Address |
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Postal Address |
Push Gaming Limited, 10th Floor, 10 East Road, London, N16AD United Kingdom |
