Chapter 1: HR Framework & Governance

Chapter 2: Attracting & Hiring Talent

Chapter 2: Attracting & Hiring Talent
HR2.1 – Recruitment & Selection Policy
Policy Statement
TopSkills is committed to transparent, merit-based, and timely recruitment processes that attract candidates with the right skills, values, and potential. Recruitment decisions are made without discrimination and in line with TopSkills’ vision of developing purpose-driven talent.

Purpose
This policy provides a standard approach for filling vacancies, ensures fairness and equal opportunity for all applicants, protects TopSkills through proper documentation and legal compliance, and safeguards the TopSkills brand in the labour market.

Scope
This policy applies to all recruitment at TopSkills, including permanent and fixed-term positions, project-based roles, internships, and, where TopSkills runs the sourcing process, locum or consultant engagements.

Guiding Principles
Merit & Competence – selection is based on job-related criteria.
Equal Opportunity – no unlawful discrimination in any stage of recruitment.
Transparency & Documentation – all key decisions are recorded and justifiable.
Speed with Quality – recruitment is timely while maintaining thoroughness.
Brand & Candidate Experience – all applicants are treated with respect and courtesy.
Roles & Responsibilities
Executive Management: approves headcount additions and may participate in final interviews for senior or critical roles.
HR Department: coordinates recruitment, ensures adherence to this policy, and maintains vacancy files and recruitment reports.
Hiring Manager: initiates the recruitment request, defines role requirements, participates in shortlisting and interviews, and recommends the preferred candidate.
Interview Panel: conducts structured interviews, evaluates candidates using agreed tools, and recommends the preferred candidate based on evidence.
Core Policy Provisions
Authorization to Recruit: no recruitment begins without an approved Requisition to Hire, signed by the relevant authority.
Job Description & Person Specification: each role must have a current JD and person specification before advertising.
Vacancy Advertisement: adverts clearly describe the role, requirements, application procedure, closing date, and identify TopSkills as an equal opportunity employer.
Shortlisting: shortlisting follows objective, pre-agreed criteria, documented via a shortlisting matrix.
Interviews & Assessments: TopSkills uses structured interviews and, where appropriate, tests or work samples applied consistently across candidates.
Reference & Background Checks: at least two referees are contacted for the preferred candidate; additional checks may be carried out for sensitive roles.
Selection & Offer: the selected candidate must meet minimum essential criteria and be the most suitable overall; HR prepares the formal offer.
Data Protection: candidate data is handled confidentially and used only for recruitment and onboarding purposes.
Recruitment of Relatives / Conflict of Interest: relationships are declared, and related staff do not participate in decision-making for the candidate.
Use of Agencies / External Platforms: third parties involved in recruitment must respect this policy and TopSkills’ standards.
SOP-HR2.1 – Recruitment & Selection
Objective
To provide a clear, repeatable process for planning, recruiting, selecting, and hiring employees at TopSkills, ensuring fairness, speed, and compliance.

Scope
This SOP applies to all recruitments initiated by TopSkills for internal staff and project-based positions.

Roles
HR Lead / HR Officer
Hiring Manager
Executive Management
Interview Panel Members
Admin / IT Support (for logistics & onboarding handover)
Procedure
Identify Need & Define Role
Hiring Manager reviews workload, budget, and structure to confirm vacancy or new role.
Drafts or updates Job Description (JD) and Person Specification.
Agrees grading and indicative salary range with HR.
Raise Recruitment Requisition
Hiring Manager completes the Requisition to Hire form, including title, reason, contract type, grade/salary range, and preferred start date.
HR reviews for completeness and confirms availability in HR plan and budget.
Executive Management approves or declines the requisition.
Prepare & Publish Advertisement
HR drafts the job advert using the JD and person specification.
Hiring Manager reviews and clears the advert.
HR posts the advert on internal and/or external platforms and logs where and when it is posted.
Receive & Acknowledge Application
sApplications are received via the designated channel and stored systematically.
HR updates an application register and may send acknowledgements.
Shortlisting
HR screens out clearly ineligible applications.
HR and Hiring Manager agree on shortlisting criteria and score each application using a Shortlisting Matrix.
Shortlist and reasons for non-shortlisted applicants are documented and signed off.
Interview Planning
HR and Hiring Manager select interview panel members.
HR prepares interview guides, scoring sheets, and any tests or tasks and schedules interviews.
Candidates receive formal invitations with full details.
Conduct Interviews & Tests
Panel members review candidate CVs and JD in advance.
Interviews follow a structured format; the same core questions are asked to all candidates.
Panel members score independently and consolidate scores and recommendations.
Reference & Background Checks
HR contacts at least two referees for the preferred candidate using a standard form.
HR verifies key documents and, for sensitive roles, coordinates additional clearances where required.
Selection Decision & Approval
The panel submits a Recruitment Summary and Recommendation to the Hiring Manager and HR.
HR checks alignment with grade, salary range, and policy.
Executive Management or delegated authority approves the final selection.
Offer & Acceptance
HR prepares and sends a formal Offer Letter to the selected candidate.
The candidate signs and returns the offer within the stated timeframe.
HR confirms acceptance and triggers the onboarding process.
Communication to Unsuccessful Candidates
Once the offer is accepted, HR sends regret emails to unsuccessful interviewed candidates.
Where possible, brief feedback is provided to shortlisted candidates on request.
Records & Forms
HR-F1: Requisition to Hire Form
HR-F2: Job Description & Person Specification Template
HR-F3: Shortlisting Matrix
HR-F4: Interview Guide & Scoring Sheet
HR-F5: Reference Check Form
HR-F6: Recruitment Summary & Recommendation Template
Key Controls & KPIs
Average time-to-fill from requisition approval to offer acceptance.
Percentage of roles filled within agreed timeframes.
Diversity indicators of applicant pool and hires.
100% of recruitments documented with requisition, shortlisting matrix, and interview scores.
HR2.2 – Employment Contracts & Classification
Policy Statement
TopSkills provides clear, legally compliant employment contracts that define the rights, duties, obligations, and terms of engagement for all categories of staff. The organisation follows principles of transparency, fairness, and compliance with the Employment Act, 2007 and other labour laws.

Purpose
This policy ensures proper classification of employees, standardisation of contract formats, legal compliance, and clear communication of expectations between TopSkills and the individuals engaged by the organisation.

Scope
This policy applies to permanent staff, fixed-term employees, project-based personnel, temporary or casual workers, interns, trainees, contractors, and Work Experience Programme (WEP) participants.

Contract Types & Classification
1. Permanent Employment: open-ended engagement for long-term organisational roles. Includes probation, full benefits, and ongoing performance obligations.
2. Fixed-Term Contract: employment with a defined start and end date based on funding cycles, project timelines, or organisational needs.
3. Project-Based Employment: tied to a specific assignment, deliverable, or consulting output. Ends automatically upon project completion unless renewed.
4. Casual Employment: temporary engagement typically paid daily. Governed by Kenyan labour law limitations and benefits provisions.
5. Internship & Traineeship: learning-focused arrangements designed to build workplace competency and exposure. May be paid or unpaid and do not automatically lead to employment.
6. Locum / Consultancy Engagement: specialised short-term engagements governed by a consultancy agreement. Not considered employment.
7. Work Experience Programme (WEP)
The Work Experience Programme (WEP) is a structured developmental pathway that supports experiential learning, workplace readiness, and professional growth. Any TopSkills staff member may sign up for WEP, creating a dual relationship where an employee may simultaneously function as a learner. External participants may also join WEP solely for learning.

Purpose of WEP Classification
WEP enables TopSkills to develop internal talent through real tasks, ongoing mentorship, soft skills development, digital literacy, HR consulting exposure, and practical work experiences. It produces a competency-based Work Experience Transcript that institutions and employers can use when assessing talent.

Characteristics of WEP Engagement
Structured learning pathway covering digital skills, task execution, professional behaviour, communication, HR consulting basics, and leadership.
Completion of real work assignments logged for learning and competency tracking.
Continuous mentorship recorded in the TopSkills Talent, Task & Performance Management System.
Tracking of task timeliness, quality, and complexity through the TopSkills internal system.
Dual identity for employees: obligations as staff remain intact while WEP tasks support learning.
Mandatory submission of timesheets, task logs, reflections, mentorship logs, and performance records.
WEP Contractual Understanding
Participation in WEP is voluntary and documented through a WEP Participation Form or a WEP Learner Agreement for non-employees. WEP does not alter employment status and does not replace job responsibilities or probation requirements. It is a developmental overlay to existing engagements.

WEP Transcript
The Work Experience Transcript includes task records, competencies demonstrated, mentorship sessions, learning reflections, supervisor reviews, and system-generated insights. It may be used for internal promotion, job placement, career planning, or institutional recruitment.

Compliance & Safeguards
WEP must not be used to replace paid labour or exploit learners.
Data collected through tasks and mentorship is governed by confidentiality and data protection policies.
WEP tasks must be manageable and must not conflict with contractual job duties.
Classification Summary for WEP Participants
CategoryRelationship to TopSkillsContract RequiredDocumentation
Employee + WEPDual: worker & learnerEmployment Contract + WEP Participation FormTimesheets, task logs, mentorship logs, transcript
WEP Learner (non-employee)Developmental onlyWEP Learner AgreementTimesheets, task logs, transcript
Contractor + WEPContractor & learnerContractor Agreement + WEP FormTask & performance records, transcript
Intern/Trainee + WEPLearning-focusedInternship/Traineeship Agreement + WEP FormLearning tasks, mentorship logs, transcript
Content of Employment Contracts
All contracts must include: employee details, job title, reporting line, contract type, duration, remuneration, benefits, working hours, leave entitlements, probation period, confidentiality clauses, data protection, termination clauses, and signatures of both parties.

Probation
Standard probation is 3–6 months and may be extended once. Performance must be reviewed before confirmation. (Detailed procedures provided in HR2.3 Probation & Confirmation.)

Contract Renewal
HR notifies the Hiring Manager 30–60 days before contract end. Renewal requires a new contract or a formal addendum. Staff must be informed of renewal or non-renewal decisions at least 30 days before the expiry date.

Contract Variation
Any change in job title, salary, working hours, duty station, or conditions must be documented through a Contract Addendum approved by HR and Executive Management.

Responsibilities
HR: drafts and reviews contracts, ensures compliance, files records, triggers renewal processes.
Hiring Manager: confirms role details and classification, ensures employee understanding.
Employee: reviews and signs contract, complies with employment and WEP terms.
SOP-HR2.2 – Employment Contracting & Classification
Step 1: Confirm Classification
HR and Hiring Manager determine the appropriate employment category based on the nature and duration of the role.

Step 2: Gather Documentation
HR collects job information and candidate documents (IDs, certificates, KRA PIN, NHIF/NSSF, bank details).

Step 3: Draft Contract
HR prepares the employment contract including standard clauses, role-specific terms, probation, and confidentiality obligations.

Step 4: Internal Review & Approval
HR and Hiring Manager review the draft. Executive Management approves the final contract.

Step 5: Issue Contract
Contract is shared with the employee for signature. HR countersigns and the hiring date is confirmed.

Step 6: Filing & HR System Update
HR uploads the signed contract, updates employee profile, sets probation and renewal reminders, and records classification.

Step 7: Renewal or Amendment
HR prepares renewal contracts, addendums, or non-renewal notices as required.

Step 8: Contract Termination & Exit Documentation
HR processes clearance, final dues, and issues a Certificate of Service in line with Chapter 6.
HR2.3 – Probation & Confirmation
Policy Statement
Probation is a structured evaluation period used to assess an employee’s suitability, performance, conduct, and cultural fit. Confirmation is not automatic; it is granted only after successful review of performance and behaviour.

Purpose
To provide a fair and transparent process for assessing new employees, ensuring performance standards are met, and identifying support required for successful integration into TopSkills.

Scope
Applies to all permanent, fixed-term, and project-based employees. Excludes contractors, casual staff, WEP-only learners, and engagements under 3 months.

Probation Duration
Standard probation is 3–6 months as stated in the employment contract.
Probation may be extended once only, for valid reasons and with written justification.
Failure to extend on time does not constitute automatic confirmation.
Short-Term Trial Contracts (Alternative to Probation)
In some cases, TopSkills may engage new workers through short-term trial contracts instead of a standard probation period. These contracts function similarly to locum or freelance engagements and allow TopSkills to assess an individual’s suitability without creating the legal expectation of continued employment associated with probation.

When Short-Term Trial Contracts Are Used
As a practical alternative to probation: a new worker may receive a short (e.g., 3-month) part-time or task-based contract to assess performance, reliability, behaviour, and suitability before considering longer-term employment.
When the nature of work is temporary, short-term, or project-based—such as administrative support during client work, data collection, research assistance, or field work for HR consulting projects.
When TopSkills requires flexibility before committing to long-term roles and needs to evaluate work quality or culture fit with real tasks.
Characteristics of Short-Term Trial Contracts
Strictly time-bound (typically 1–3 months).
May be part-time, hourly, or task-based.
No assumption of automatic continuation after expiry.
Not considered probation under employment law.
Performance is continuously assessed throughout the contract.
At the end of the contract, individuals may transition to regular employment (with probation), receive another short-term contract, or complete their engagement.
Documentation Requirements
Short-term trial contracts must clearly state the duration, payment structure, tasks or deliverables, performance expectations, and that the engagement does not guarantee continuation or constitute probation.

Expectations During Probation
Achievement of role-specific KPIs and tasks.
Demonstration of professionalism and cultural alignment.
Attendance, punctuality, reliability, and adaptability.
Completion of onboarding and required learning modules.
Probation Reviews
Early Check-In (Week 1–2): clarity of expectations and initial feedback.
Mid-Probation Review (Month 2–3): structured assessment and improvement planning.
Final Review (Month 3–6): decision on confirmation, extension, or non-confirmation.
Confirmation
Employees are confirmed when they meet performance, behavioural, and training expectations. HR issues a formal Confirmation Letter following management approval.

Non-Confirmation
Employment may be terminated if performance or conduct remains below expectations. A fair review and written notice are required.

WEP Participants Who Are Employees
WEP activities do not replace probation requirements. Only job-related performance determines confirmation. WEP tasks may support evidence of learning but are not used for contractual decisions.

Responsibilities
HR: tracks timelines, supports managers, manages documentation.
Manager: conducts reviews and recommends confirmation, extension, or exit.
Employee: performs duties to expected standards and participates in feedback processes.
SOP-HR2.3 – Probation & Confirmation Process
Step 1: Onboarding & Expectation Setting
Manager and HR clarify KPIs and onboarding expectations within the first 7 days.

Step 2: Early Check-In
Manager provides initial feedback and identifies training needs within the first two weeks.

Step 3: Mid-Probation Review
A structured review takes place around months 2–3.

Step 4: Final Review
Manager evaluates performance and recommends confirmation, extension, or non-confirmation.

Step 5: HR Decision & Approvals
HR reviews documentation and Executive Management approves the final decision.

Step 6: Communication
HR issues the appropriate letter and meets the employee.

Step 7: Record Management
HR files review forms and updates the employee profile.

Forms & Templates
HR-F12: Probation Objectives & Onboarding Checklist
HR-F13: Mid-Probation Review Form
HR-F14: Final Probation Evaluation Form
HR-F15: Probation Extension Letter
HR-F16: Confirmation Letter
HR-F17: Non-Confirmation Letter
HR2.4 – Internal Transfers, Role Changes & Promotions
Policy Statement
TopSkills encourages internal mobility, role development, and fair advancement based on merit, organisational need, and demonstrated competence. Internal movements must be structured, documented, and aligned with the organisation’s performance and competency frameworks.

Purpose
To ensure consistent, transparent, and fair processes for internal transfers, role changes, and promotions; to strengthen talent development; and to align skills with organisational requirements.

Scope
Applies to permanent, fixed-term, and project-based employees, including WEP participants who are also employees. Excludes independent contractors, external WEP learners, and short-term trial contracts.

Definitions
Lateral Transfer: movement to another role at the same level or grade.
Role Change: adjustment of duties due to restructuring, skills growth, or operational needs.
Promotion: movement to a role with greater responsibility, higher complexity, or higher grade.
Eligibility
Minimum 6 months in current role (unless waived).
Satisfactory performance and behaviour.
No active disciplinary cases.
Skills match for the new role.
Promotion Criteria
Strong Balanced Scorecard results.
Evidence of competence at the next level.
Positive behaviour and values alignment.
Organisational need and role availability.
Types of Promotion
Vertical Promotion
Skills-Based Promotion
Project-Based Promotion
Acting Promotion
Documentation
Internal Transfer Letter
Role Change Addendum
Promotion Letter
Updated Job Description and KPIs
Responsibilities
HR: ensures compliance, prepares documentation, updates HRIS.
Manager: initiates requests, provides evidence, manages handover.
Employee: assumes new duties and participates in assessments.
Executive Management: approves major promotions or structural changes.
SOP-HR2.4 – Internal Transfers, Role Changes & Promotions
Step 1: Initiation
Manager or employee submits a request. HR verifies eligibility and organisational needs.

Step 2: Review
HR reviews performance history, BSC results, WEP transcripts (if applicable), and competence.

Step 3: Evaluation
Panel or manager evaluates suitability through interviews or competency checks.

Step 4: Approval
HR prepares documentation for Executive Management approval where applicable.

Step 5: Documentation & Notification
HR issues movement letters and updates job descriptions and KPIs.

Step 6: Transition
Employee completes handover and assumes new role. HR updates HRIS.

Step 7: Post-Movement Review
Manager evaluates adaptation within 1–3 months and provides support if required.
HR2.5 – Acting Appointments & Interim Roles
Policy Statement
Acting appointments allow employees to temporarily assume higher or different responsibilities to ensure continuity of service and support organisational needs. These appointments are temporary and do not guarantee promotion.

Purpose
To provide clear guidance on assigning acting or interim roles, ensure fairness, maintain operational continuity, and support staff development through temporary leadership exposure.

Scope
Applies to permanent, fixed-term, and project-based staff, including WEP participants who are employees. Excludes contractors, external WEP learners, and short-term trial contract staff.

Definition of Acting Appointment
Temporary assumption of duties of a higher or different role.
Used when a position is vacant, during staff absence, or for temporary project leadership.
Acting roles may be interim (less than 1 month), extended (1–6 months), or project-based.
Eligibility
Satisfactory performance and behaviour.
Competence and readiness for the acting role.
No active disciplinary matters.
Compensation
Acting allowance may be granted when the acting period exceeds 14 consecutive days and the employee performs substantive duties of the higher role. Allowance levels depend on grade differences and must be approved by Executive Management.

Duration of Acting Roles
Minimum duration: 3 days.
Maximum typical duration: 6 months.
Extensions require justification and Executive approval.
Documentation
Acting Appointment Letter.
Temporary duty list and expected deliverables.
Allowance or compensation changes, if applicable.
End-of-acting evaluation and reversion notice.
Performance Evaluation
Acting duties form part of the performance review using Balanced Scorecard metrics and competency assessments. WEP transcript insights may support evaluation.

SOP-HR2.5 – Acting Appointment Process
Step 1: Identify Need
Manager identifies vacancy or absence and submits request to HR.

Step 2: Eligibility Review
HR evaluates performance history, competence, and readiness.

Step 3: Recommendation & Approval
Manager submits justification; HR reviews; Executive Management approves.

Step 4: Documentation
HR issues Acting Appointment Letter and updates HRIS.

Step 5: Role Execution
Employee performs acting duties with supervisor support.

Step 6: Mid-Review
Manager reviews progress if acting period exceeds one month.

Step 7: End-of-Acting Review
Manager evaluates achievements and growth; HR records outcomes.

Step 8: Reversion
Employee returns to substantive role unless formally appointed otherwise.
HR2.6 – Job Analysis, Job Evaluation & Assignment of Salary Grades
HR2.6.1 Policy Statement
TopSkills uses a structured, evidence-based approach to analyse jobs, evaluate their relative value, assign salary grades, and benchmark salaries and benefits against the external market. Job evaluation focuses on the job, not the person, and supports internal equity, transparency, and competitive compensation.

HR2.6.2 Purpose
This chapter provides a standard methodology for conducting job analysis, job evaluation, designing salary grades, and undertaking salary and benefits benchmarking. It allows TopSkills and its clients to maintain fair, competitive, and systematic reward structures across different sectors.

Maintain accurate job descriptions through systematic job analysis.
Evaluate job roles using a point–factor model and compensable factors.
Support the design of salary structures and grading systems.
Provide a consulting-ready methodology for salary surveys and benchmarking projects.
Ensure internal equity and alignment to market competitiveness.
HR2.6.3 Scope
The policy applies to all permanent, fixed-term, and project-based employee roles within TopSkills, as well as to job evaluation and salary benchmarking assignments conducted for clients. It does not govern the fee-setting of independent contractors or external Work Experience Programme learners.

HR2.6.4 Definitions
Job Analysis: Systematic study of a job to identify its purpose, tasks, required skills, education, experience, and responsibilities.
Job Evaluation (JE): A structured process used to determine the relative value of jobs by assessing compensable factors and assigning point values.
Compensable Factors: Standardised job elements used to determine job complexity and value, grouped under Skill, Responsibility, Effort and Working Conditions.
Salary Benchmarking: Comparison of internal pay and benefits against market trends and competitor organisations.
HR2.6.5 Job Analysis Policy
Every position must have an up-to-date Job Description (JD) that outlines the job purpose, key responsibilities, reporting relationships, minimum qualifications and experience, required competencies, and KPIs.

Job analysis is required when new roles are created, existing roles change significantly, or when a job is being evaluated or benchmarked. Methods may include document review, interviews, questionnaires, and observation. The analysis focuses on job content, not the incumbent.

HR2.6.6 Job Evaluation Framework (Point–Factor Method)
TopSkills uses a point–factor job evaluation method, suitable across different sectors. Jobs are evaluated using compensable factors, each with structured levels and point values. Total points determine the job’s relative value and salary grade.

a) Compensable Factors (General Across All Sectors)
The compensable factors used by TopSkills are designed for broad applicability across sectors including healthcare, financial services, NGOs, public sector, technology, education, manufacturing and others. The factors measure job requirements, not individual capability.

Skill
Education & Professional Knowledge: Required level of formal education, technical knowledge or professional qualifications.
Experience: Years and depth of relevant experience needed to perform effectively.
Analysis & Judgement: Level of problem-solving, decision-making and analytical thinking required by the job.
Responsibility
Freedom to Act (Autonomy): Level of independence, discretion and supervision.
Impact of Decisions: Influence on financial results, service quality, compliance, risk or organisational reputation.
Communication & Influence: Extent of stakeholder engagement, negotiation, coordination and influence internally and externally.
People Leadership / Supervision: Responsibility for guiding, supervising or developing staff, contractors or teams.
Responsibility for Financial & Material Resources: Budgets, assets, systems or information under the job’s control.
Effort
Mental Effort: Cognitive load, concentration, multi-tasking and attention to detail.
Physical Effort: Any physical activity such as standing, lifting, travelling or field work.
Working Conditions
Work Environment & Risk: Exposure to demanding environments such as tight deadlines, frequent travel, remote fieldwork, safety-sensitive contexts, or high regulatory and compliance risk.
Each factor has pre-defined levels with point values. The Job Evaluation Committee selects the most appropriate level for each factor and the total score determines the job grade.

b) Job Evaluation Committee (JEC)
Composed of at least five trained members representing HR and operational units.
Ensures objectivity and consistency.
Members must declare conflicts of interest and may step aside when necessary.
Decisions are made by consensus and fully documented.
c) Steps for Conducting Job Evaluation
Confirm or update job analysis and job description.
Select benchmark roles for aligning job levels.
Evaluate the job by assigning factor levels.
Convert levels into points using the point–factor matrix.
Map the job to a salary grade based on total points.
Conduct internal equity checks for consistency.
Submit results for approval and communicate outcomes.
HR2.6.7 Salary Grades & Pay Ranges
Jobs with similar point totals are grouped into salary grades. Each grade has a minimum, midpoint and maximum salary range. Actual grade definitions may vary by organisational structure.

GradeRole LevelExample RolesCompetency Band
G1Entry / SupportAssistants, Clerks, Trainee rolesLearner / Operative
G2Junior OfficerHR Officer I, Admin Officer IOperative / Specialist
G3Officer / SpecialistHR Officer II, Consultant ISpecialist
G4Senior SpecialistConsultant II, Project CoordinatorAdvanced Specialist
G5ManagerialHR Manager, Senior ConsultantManager
G6Senior Manager / LeadProgramme Lead, Lead ConsultantExpert
HR2.6.8 Salary & Benefits Benchmarking
Salary and benefits benchmarking is used to compare internal compensation with external markets and support strategic reward decisions. TopSkills applies a structured six-phase approach suitable for consulting assignments across different sectors.

a) Objectives
Determine competitiveness of salaries, allowances and benefits.
Align compensation with attraction and retention needs.
Support reward policy decisions with credible evidence.
b) Six-Phase Benchmarking Method
Role Identification & Job Matching: Confirm roles to benchmark and align them with internal or sector job descriptions.
Tool Design: Develop data collection tools covering pay, allowances, benefits and reward practices.
Comparator Engagement: Identify and invite comparator organisations, ensuring confidentiality and secure data handling.
Data Collection: Collect data through templates, meetings and clarifications.
Analysis & Benchmarking: Clean, validate and compare market statistics such as medians and percentiles.
Reporting & Recommendations: Present findings, gaps and strategic options to management.
HR2.6.9 Governance, Roles & Responsibilities
Board / Directors: Approve salary structures and policy changes.
Executive Management: Approve JE outcomes, salary grades and benchmarking results.
HR / Rewards Unit: Lead job analysis, JE, salary structure design and salary surveys; maintain tools and records.
Line Managers: Provide accurate job information and support JE processes.
Job Evaluation Committee: Apply the JE tool objectively and ensure consistency.
SOP-HR2.6A – Job Evaluation Procedure
Initiate JE request and confirm evaluation scope.
Update job description through job analysis.
Prepare evaluation documents.
Convene JEC and assign factor levels.
Total points and map job to a grade.
Submit evaluation for approval.
Communicate the decision and update records.
SOP-HR2.6B – Salary Benchmarking Procedure
Conduct scoping meeting and confirm roles.
Develop or refine data collection tools.
Engage comparator organisations.
Collect, validate and verify data.
Analyse results and identify gaps.
Prepare and present final report and recommendations.
HR2.7 – Regrading & Salary Adjustment Rules
HR2.7.1 Policy Statement
TopSkills recognises that jobs and markets change over time. To maintain fairness and competitiveness, the organisation uses clear rules for regrading jobs and adjusting salaries. Decisions are based on job value, performance and market data, not ad hoc requests.

HR2.7.2 Purpose
This policy defines when and how job grades may be changed and when salary adjustments are appropriate. It ensures that changes are transparent, consistent, affordable and aligned with the job evaluation and salary benchmarking framework set out in HR2.6.

HR2.7.3 Scope
The rules apply to all permanent, fixed-term and project-based employees whose roles have been graded under the TopSkills job evaluation system. Independent contractors and external Work Experience Programme (WEP) learners are governed by separate arrangements.

HR2.7.4 Key Definitions
Regrading: Changing the salary grade of a job following formal job evaluation.
Salary Adjustment: Changing an individual’s salary within or between grades for an approved reason.
Pay Range: The minimum, midpoint and maximum salary associated with a grade.
Compression: A situation where pay differences between roles of different seniority or tenure become too narrow or reversed.
HR2.7.5 Guiding Principles
Job-based: Regrading is driven by job content and job evaluation, not personal financial needs.
Internal Equity: Similar roles at the same grade should have broadly comparable pay, adjusted for performance and experience.
Market Alignment: Where proven gaps exist relative to the market, adjustments may be made using structured, data-driven approaches.
Budget Discipline: All changes must be affordable and, if needed, phased over time.
Documentation & Transparency: Each decision must be documented with clear reasons and approvals.
No Automatic Entitlement: Requests for higher pay or grade do not guarantee changes.
HR2.7.6 Regrading of Jobs
a) When Regrading May Be Considered
A job may be considered for regrading when:

Its responsibilities have changed substantially and permanently.
It has been redesigned, merged or significantly expanded in scope.
Organisational restructuring has altered its level of accountability.
Job evaluation or benchmarking suggests that the job’s relative level has shifted.
Regrading is not used simply to reward strong performance or to respond to individual cost-of-living concerns.

b) Regrading Process
Request: The manager submits a regrading request and updated job description to HR.
Verification: HR confirms that changes are substantial and role-related.
Job Evaluation: The Job Evaluation Committee reassesses the job using the approved tool.
Grade Decision: HR maps the new points to the appropriate grade.
Approval: Executive Management reviews and approves or declines the regrading.
Communication: HR informs the manager and jobholder of the outcome.
Implementation: HR updates records and, where applicable, applies related salary adjustments.
HR2.7.7 Salary Adjustment Rules
Salary adjustments may arise from one or more of the following:

Promotion or upward regrading.
Market alignment adjustments following salary surveys.
Merit or performance-based increases within grade.
Equity corrections and compression management.
General or cost-of-living adjustments, where approved.
a) Promotion / Upward Regrading
When an employee is promoted or their job is regraded upward, the salary should normally move into the new grade range and be higher than the previous salary, subject to internal guidelines and grade maximums.

b) Market Adjustments
Based on salary benchmarking results, TopSkills may adjust pay for roles or grades that are significantly misaligned with the market. Adjustments may be prioritised and phased, focusing on critical roles and significant gaps.

c) Merit / Performance Increases
Within a grade, employees may progress through the pay range based on performance results, increased competence and achievement of development plans. Merit awards are linked to the performance management cycle and should be differentiated based on performance level.

d) Equity / Compression Adjustments
Where unjustified pay gaps or compression are identified between employees in similar roles and grades, HR may recommend adjustments to restore equity, subject to budget and approval.

e) General or Cost-of-Living Adjustments
From time to time, TopSkills may approve general increases or cost-of-living adjustments. These are usually applied systematically across certain grades or the whole organisation, based on affordability and economic conditions.

HR2.7.8 Limitations & Safeguards
Employees should not normally be paid above the maximum of their salary range.
Managers may not promise pay or grade changes without formal approval.
All decisions must be supported by documentation and be open to audit.
HR2.7.9 Special Considerations: WEP & Short-Term Contracts
WEP participants who become employees are placed into appropriate grades using job evaluation and may have their starting salary informed by their WEP performance and competencies. Short-term or project contracts may use fixed fees or rates; when such staff transition into longer-term employment, their salary is aligned to the applicable grade and pay range.

SOP-HR2.7A – Regrading Procedure
Manager submits a regrading request and updated job description to HR.
HR verifies the nature and permanence of the changes.
The Job Evaluation Committee reassesses the job and assigns a point score.
HR maps points to the appropriate grade and prepares a recommendation.
Executive Management approves or declines the recommendation.
HR communicates the decision and updates the job grade and records.
SOP-HR2.7B – Salary Adjustment Procedure
Identify the reason for the proposed adjustment (promotion, market, merit, equity, COLA, etc.).
HR reviews relevant data (evaluation, performance ratings, benchmarking results).
HR prepares a proposal showing current and proposed salary and rationale.
Executive Management or delegated authority approves or rejects the proposal.
HR or the manager communicates the decision and effective date to the employee.
Payroll and HR records are updated accordingly.
HR2.8 – Change Management & Organisational Redesign
HR2.8.1 Policy Statement
TopSkills recognises that organisations must continually adapt to remain sustainable, efficient and responsive to technological, operational, economic and market changes. This policy outlines how TopSkills manages organisational redesign, restructuring, job changes and workforce adjustments. It also sets employee expectations that while contracts provide stability, roles may change and, in certain circumstances, contracts may cease, subject to full compliance with the Employment Act.

HR2.8.2 Purpose
The purpose of this policy is to provide a structured and transparent approach to organisational change, clarify the organisation’s right to redesign roles and staffing structures, and ensure that all workforce changes comply with Kenyan labour laws while upholding fairness, dignity and business sustainability.

HR2.8.3 Scope
This policy applies to all employees, including permanent, fixed-term and project-based staff. It also applies to roles transitioning from the Work Experience Programme (WEP) into employment. Independent contractors are excluded.

HR2.8.4 Triggers for Organisational Change
Technological advancements: automation, AI adoption, or digital workflow redesign.
Financial or economic pressures: loss of key clients, reduced revenue, or sustainability challenges.
Operational or strategic shifts: restructuring to improve efficiency or realign functions.
External events: epidemics, national crises or regulatory changes.
Performance or business model changes: introduction of new delivery models or consolidation of roles.
HR2.8.5 Guiding Principles
Transparency and timely communication.
Full compliance with the Employment Act.
Dignity, fairness and respect for all staff.
Business sustainability and organisational viability.
Competency-based redeployment where possible.
Documentation and proper approvals for all decisions.
HR2.8.6 Staff Expectations
Employees should expect that roles may evolve due to organisational needs. Responsibilities may change, reporting lines may shift, and redeployment may occur where skills match available roles. In cases where no suitable role exists or restructuring requires workforce reduction, contracts may cease, following full legal compliance including notice, severance (where applicable), and issuance of a certificate of service.

HR2.8.7 Redeployment Rules
Redeployment is prioritised before separation.
Matching is based on competence, performance and business needs.
Salary alignment follows HR2.7 guidelines.
If redeployment is not possible, legal separation procedures apply.
HR2.8.8 Organisational Redesign Process
Organisational redesign may involve updating structures, merging roles, eliminating duplication, adjusting reporting lines or introducing technology-driven changes. Where job content changes substantially, job evaluation and regrading processes (HR2.6 and HR2.7) apply.

HR2.8.9 Legal Compliance
All workforce reductions or contract cessations will follow the Employment Act, including:

Redundancy notices to employees and the labour office.
Selection criteria based on skill, performance, reliability and tenure.
Severance pay where required.
Payment of accrued dues and issuance of a certificate of service.
HR2.8.10 Communication Standards
Clear explanation of the change and its rationale.
Respectful, confidential and timely communication.
Provision of support where feasible.
HR2.8.11 Special Considerations: Work Experience Programme (WEP)
WEP participants are learners and not employees; however, organisational changes may adjust the structure of WEP activities. For WEP participants transitioning to employment, changes in organisational structure may influence placement and job availability.

SOP-HR2.8A – Organisational Change Management Procedure
Identify the trigger for organisational change.
HR prepares a Change Impact Assessment.
Executive Management reviews and approves the plan.
HR redesigns the organisational structure and updates role profiles.
Job evaluation conducted for revised roles.
Redeployment assessment for affected staff.
Consultation meetings with employees.
Legal compliance steps executed (notices, severance, dues).
Implementation of redeployment or separation.
Post-change review and communication of the updated structure.
HR2.9 – Talent Pipeline & Prequalification
HR2.9.1 Policy Statement
TopSkills builds and maintains structured talent pipelines and prequalified talent pools to support faster, higher-quality recruitment and deployment. These pipelines may include past applicants, Work Experience Programme (WEP) participants, mentees, independent contractors and sector specialists who have met defined minimum standards through screening, assessment or prior engagement.

HR2.9.2 Purpose
The purpose of this policy is to define how TopSkills creates, manages and uses talent pipelines and prequalified rosters, both for internal staffing and for recruitment assignments conducted on behalf of clients. It ensures fairness, transparency and compliance with data protection principles.

HR2.9.3 Scope
This policy covers all structured talent pools managed by TopSkills, including internal pipelines, WEP and mentorship pipelines, independent contractor rosters and role-specific candidate pools. It does not cover informal contact lists or individuals who have not consented to be part of a talent pool.

HR2.9.4 Definitions
Talent Pipeline: A structured sequence of potential candidates who are being identified, engaged or developed for current or future opportunities.
Talent Pool / Roster: A group or database of candidates who have been prequalified for certain job categories or levels.
Prequalification: The process of screening and assessing candidates in advance to determine whether they meet agreed standards.
Active Pool: Candidates who are responsive and whose details have been recently updated.
Dormant Pool: Candidates whose information is outdated or who have not responded to recent communication.
HR2.9.5 Types of Talent Pipelines
Internal Talent Pipeline: Current employees and WEP graduates identified for future roles or higher responsibilities.
WEP & Mentorship Pipeline: Learners progressing through defined levels whose performance and competencies are tracked for potential employment.
Independent Contractor & Consultant Pipeline: Prequalified professionals available for project-based work.
Role-Specific Candidate Pipelines: Pools created for recurring roles such as HR Officers, ICT Support, Finance staff, etc.
Client-Specific Talent Pools: Dedicated pools created for particular clients, where agreed in the consulting engagement.
HR2.9.6 Principles
Consent & Data Privacy: Candidates are informed and must consent for their data to be retained in talent pools.
Fairness & Non-Discrimination: Entry into pools is based on clear criteria, not on protected characteristics.
Clarity of Levels: Candidates are categorised by level (e.g. junior, specialist, senior) and, where relevant, by WEP/mentorship level.
Regular Updating: Talent pools are periodically refreshed to maintain accuracy.
No Guaranteed Employment: Being in a pool increases visibility but does not guarantee a job or contract.
HR2.9.7 Prequalification Criteria
Criteria vary by pool but may include minimum education, relevant experience, technical skills, behavioural competencies, performance in interviews or tests, and, for WEP participants, performance and competence demonstrated during the programme. For independent contractors, additional criteria may include prior assignments, references and compliance with registration requirements.

HR2.9.8 Talent Pipeline Stages
Attraction & Registration: Individuals register interest through portals, applications, WEP forms or project adverts.
Screening & Prequalification: HR reviews applications against predefined standards.
Pool Admission: Suitable candidates are admitted into relevant talent pools.
Engagement & Development: Candidates may receive resources, mentorship or limited assignments.
Opportunity Matching: When vacancies arise, suitable candidates are searched and shortlisted from the pool.
Selection & Placement: Standard recruitment or contracting processes are followed to select and engage candidates.
Feedback & Status Updating: Candidate statuses are updated (e.g. hired, not selected, dormant).
HR2.9.9 Use of Talent Pipelines for Clients
When engaged by clients to recruit, TopSkills may use its talent pools to accelerate shortlisting, subject to client agreement and data protection requirements. Clients retain final decision-making authority over appointments.

HR2.9.10 Governance & Responsibilities
Board / Directors: Approve overall talent pipeline strategy.
Executive Management: Approve key talent pools and prequalification criteria.
HR / Talent Acquisition: Design, manage and maintain talent pools.
WEP & Mentorship Coordinators: Provide performance and competency data on participants.
Project Leads / Consultants: Identify and refer high-potential candidates for inclusion.
SOP-HR2.9A – Talent Pipeline & Prequalification Procedure
Define the objective and scope of the talent pool.
Agree the prequalification criteria and levels.
Set up data capture mechanisms (forms, portals, WEP systems).
Screen applications and assess candidates against the criteria.
Decide on prequalification and categorise candidates into appropriate pools.
Obtain consent and communicate pool status and expectations to candidates.
Maintain and periodically refresh candidate information and statuses.
Search and draw from relevant talent pools when vacancies or assignments arise.
Record recruitment outcomes and update the pool to improve quality over time.

Chapter 3: Onboarding, Development & Talent Systems

HR3.1 – Onboarding & Induction Policy
HR3.1.1 Policy Statement
TopSkills is committed to ensuring a structured onboarding process that helps new employees integrate quickly and effectively into the organisation. Onboarding begins before the employee’s first day and includes induction, training, role orientation and ongoing support throughout the initial period of employment.

HR3.1.2 Purpose
This policy establishes a standard approach to onboarding that promotes consistency, role clarity, early performance alignment and positive employee experience. It also supports smooth transitions for WEP graduates and internal staff moving into new roles.

HR3.1.3 Scope
The policy applies to all new employees, including permanent, fixed-term, project-based and trial contracts, as well as WEP graduates transitioning into employment. Independent contractors follow separate guidelines.

HR3.1.4 Definitions
Onboarding: A structured process of integrating a new employee into the organisation.
Induction: The initial orientation covering organisational overview, policies and expectations.
Pre-Onboarding: Preparatory activities before an employee's start date.
Buddy/Mentor: A colleague assigned to support the new employee’s transition.

HR3.1.5 Onboarding Principles
Consistency for all employees.
Purposeful communication and role clarity.
Timely preparation of tools and access.
Supportive, inclusive integration into teams.
Documented onboarding activities and checkpoints.

HR3.1.6 Onboarding Components
A. Pre-Onboarding
Issue offer letter and contract.
Collect compliance documents (ID, certificates, bank details, NHIF/NSSF).
Prepare system access and work tools.
Share Day 1 agenda and welcome communication.
B. Day 1 Induction
Organisation overview and culture.
Review of HR policies and Code of Conduct.
Orientation on communication tools and systems.
Health, safety and security basics.
C. Role Orientation
Review job description and KPIs.
Assign initial tasks and responsibilities.
Clarify reporting lines and workflow expectations.
Introduce role-specific tools.
D. Training & Access
System and tools training.
Performance management system orientation.
Department-specific training.
E. Buddy/Mentor Assignment
A buddy or mentor may be assigned to support the employee during the first weeks.

F. Follow-Up Check-ins
Week 1 review.
30-day check-in.
60-day review.
90-day onboarding confirmation.
HR3.1.7 Documentation
HR maintains an Onboarding Checklist capturing all induction and access steps, policy acknowledgements, training attendance and system activation.

HR3.1.8 Responsibilities
HR: Coordinates onboarding and induction.
Line Manager: Provides role clarity and performance expectations.
IT/Systems Support: Sets up access and tools.
Buddy/Mentor: Supports informal integration.
New Employee: Actively participates in onboarding activities.
SOP–HR3.1A: Onboarding & Induction Procedure
HR initiates pre-onboarding and prepares contract and documentation.
IT sets up systems and email access.
HR conducts Day 1 induction.
Manager provides job-specific orientation.
Week 1, 30-day, 60-day and 90-day reviews conducted as scheduled.
HR documents completion of onboarding.
HR3.2 – Employee Training & Development Policy
HR3.2.1 Policy Statement
TopSkills is a learning organisation committed to the continuous growth of its people. Employee development is supported through structured training, experiential learning, mentorship and integration with the Work Experience Programme (WEP). Employees may use WEP modules, tasks and competency frameworks to strengthen skills relevant to internal roles and client-facing assignments.

HR3.2.2 Purpose
This policy defines how TopSkills identifies, plans, implements and evaluates employee training and development. It incorporates WEP pathways to support practical, real-world skill building and alignment with the organisation’s talent progression model.

HR3.2.3 Scope
The policy applies to all employees, including those transitioning from the WEP. Employees may continue using selected WEP modules and tasks for professional development. WEP policies for non-employees remain separate.

HR3.2.4 Definitions
Training: Structured learning for current job performance.
Development: Long-term growth and progression activities.
WEP Modules: Experiential learning tasks and training used across the Work Experience Programme.
WEP Transcript: A record of competencies, tasks and performance used to inform development plans.
IDP: Individual Development Plan for employees.

HR3.2.5 Guiding Principles
WEP Integration: Employees may use WEP modules to build consulting, technical and soft skills.
Performance-Driven: Development is informed by performance results and WEP transcripts.
Learning Culture: Continuous improvement is encouraged through practice and reflection.
Fair Access: Training opportunities are aligned to roles, needs and potential.

HR3.2.6 Types of Training & Development
Mandatory Training: Policies, compliance and client-required modules.
Role-Specific/Technical Training: HR consulting, analysis, digital tools and other job-related competencies.
Soft Skills Training: Communication, teamwork, problem-solving and service delivery.
Leadership Development: Coaching, supervision and leading WEP or project teams.
WEP-Integrated Training: WEP modules, tasks, assignments and competency challenges used as employee development tools.
Communities of Practice: Peer-led learning and practice groups.

HR3.2.7 Training Needs Identification
Training needs are identified from performance reviews, WEP transcripts (for transitioning employees), client feedback, task performance, job requirements and organisational changes. Each employee maintains an updated IDP.

HR3.2.8 Planning & Prioritisation
HR consolidates needs into a training plan.
Priority is given to high-impact roles and critical competencies.
WEP modules may be used to reduce cost and provide practical learning.
Employee-initiated training proposals are considered when aligned to business needs.

HR3.2.9 Delivery Methods
In-house workshops and digital learning.
On-the-job coaching and feedback.
WEP task-based assignments for real-world practice.
Communities of practice.
External training where approved.

HR3.2.10 Evaluation of Training
Training is evaluated for relevance, learning outcomes, application and results. Performance changes, task quality, timeliness (mirroring WEP scoring) and client outcomes inform effectiveness.

HR3.2.11 Responsibilities
HR/L&D: Designs frameworks, integrates WEP modules and tracks outcomes.
Managers: Identify training needs, assign WEP-based practice tasks and monitor application.
WEP Coordinators: Provide learning modules and transcripts to support development.
Employees: Participate actively and apply learning.
Senior Management: Sets learning priorities and approves budgets.
SOP–HR3.2A: Training & Development Procedure
Identify needs through reviews and WEP competency insights.
HR prepares a training plan and integrates appropriate WEP modules.
Management approves training priorities.
Training and WEP-based learning tasks are delivered.
Follow-up assessments evaluate skill application and performance changes.
HR documents participation and updates training records.
SOP–HR3.2B: Individual Development Plans (IDPs) & WEP-Linked Development
Initiate IDP Discussion: The line manager and employee hold a development-focused conversation, reviewing role expectations and, where applicable, the employee’s WEP transcript.
Review Inputs: Consider job description, performance results, client feedback, WEP records (for former WEP participants) and anticipated changes in role or tools.
Identify Priority Development Areas: Agree on 3–5 key skills or competencies to develop, linked directly to current or future job requirements.
Agree Development Actions: Specify concrete actions such as on-the-job tasks, participation in WEP modules, mentoring/coaching, formal training or self-study outputs.
Set Timelines & Success Indicators: Define target dates and how progress will be measured (e.g. improved task quality, timeliness, independence, client feedback).
Document the IDP: Complete the standard IDP template, signed or acknowledged by both employee and line manager, and share a copy with HR.
Implement & Support: The manager assigns relevant tasks and WEP-linked activities; HR facilitates access to training; the employee actively follows the plan.
Mid-Term Review: Conduct at least one check-in to monitor progress, resolve barriers and adjust actions if needed.
End-of-Cycle Review: Evaluate completion of the IDP at the next performance review and agree on new focus areas.
Link to Talent & Succession Planning: HR uses IDP outcomes when assessing talent pipelines, internal mobility and succession planning.
HR3.3 – Training & Professional Memberships Policy
HR3.3.1 Policy Statement
TopSkills supports employee learning through sponsorship of training, certifications, conferences and professional memberships that enhance competence and organisational impact. Support may include full or partial sponsorship, study leave, CPD opportunities and use of WEP learning streams.

HR3.3.2 Purpose
This policy establishes criteria and procedures for approving external training and memberships, defining sponsorship, bonding, reimbursement requirements and CPD expectations.

HR3.3.3 Scope
Applies to all employees including those transitioning from WEP. Does not apply to non-employee WEP participants or independent contractors unless specified.

HR3.3.4 Definitions
Professional Membership: Subscription to recognised bodies relevant to professional practice.
CPD: Continuous Professional Development activities that maintain competence.
Sponsorship: Full or partial financial support for training or membership.
Bonding: Commitment to remain with the organisation after sponsorship.

HR3.3.5 Categories of Support
Fully Sponsored Training: For essential or high-impact learning.
Partially Sponsored Training: For useful but non-essential training.
Professional Membership Support: For memberships advancing organisational credibility and CPD.
Study Leave: For approved examinations.
WEP-Integrated Learning: Employees may use WEP modules for practical skill building.

HR3.3.6 Eligibility Criteria
Training relevance to current or future roles.
Good performance and learning commitment.
Pre-approval before enrolment.
Budget availability.

HR3.3.7 Bonding Requirements
High-cost training may require bonding for 6–24 months depending on sponsorship level. Early exit may require refund of costs as per agreement.

HR3.3.8 Reimbursement Procedures
Pre-approval and submission of receipts, proof of payment and completion documents are required for reimbursement.

HR3.3.9 CPD Expectations
Employees must maintain updated professional knowledge.
Participation in in-house and WEP-learning events is encouraged.
Employees maintain a CPD log and share outcomes with HR.

HR3.3.10 Responsibilities
Employee: Apply, attend and share learning.
Manager: Recommend and support learning application.
HR: Review requests and manage sponsorship records.
Management: Approve major training budgets.
SOP–HR3.3A: Training & Membership Sponsorship Procedure
Employee submits request with course or membership details.
Manager reviews relevance and endorses.
HR assesses eligibility and budget; determines bonding.
Approval issued by HR or management.
Employee attends training and completes all requirements.
Employee submits proof of completion; HR updates records.
SOP–HR3.3B: Bonding, Commitments & Post-Training Obligations
Determine Bonding Requirement: Bonding applies for high-cost or strategically important training. HR assesses cost, duration, performance and organisational priorities before deciding.
Define Bond Period: Bond duration is proportional to training cost and impact. Typical ranges: 6–12 months for short courses, 12–24 months for certifications, and 18–36 months for major programmes.
Draft & Sign Bond Agreement: HR prepares an agreement outlining sponsorship value, bond duration, obligations and repayment rules. Employee must sign before beginning training.
Post-Training Learning Application: Employees must apply learning through assignments, sharing sessions, WEP mentorship and service improvement. HR tracks learning through reviews and manager feedback.
Early Exit Before Bond Expiry: Employees leaving early must repay a prorated portion of sponsorship: Repayment = (Remaining Bond Months / Total Bond Months) × Sponsorship Amount. Waivers may be granted only by senior management.
Completion of Bond Period: HR issues a Bond Completion Letter and updates the employee’s record.
Record-Keeping: HR maintains agreements, training approvals, CPD logs and bond tracking data for audit and consistency.
HR3.4 – Job Description Management Policy
HR3.4.1 Policy Statement
TopSkills maintains clear and up-to-date job descriptions for all roles to ensure role clarity, support performance management, guide job evaluation and enable effective recruitment and training.

HR3.4.2 Purpose
This policy provides a standardised approach for creating, reviewing and approving job descriptions, ensuring they align with organisational goals and consulting work requirements.

HR3.4.3 Scope
Applies to all employees and roles created for internal functions or client projects, including WEP graduates transitioning into employment.

HR3.4.4 Definitions
Job Description (JD): Document outlining role purpose, duties and competencies.
Core Duties: Primary ongoing responsibilities.
Project Duties: Responsibilities linked to specific assignments.
Competencies: Knowledge, skills and behaviours required for performance.

HR3.4.5 Components of a Job Description
Job title
Department
Reporting line
Job purpose
Key duties (core and project-based)
Performance indicators
Qualifications & experience
Technical & behavioural competencies
Working conditions
Grade/level

HR3.4.6 Relationship With HR Processes
Recruitment: JDs guide job adverts and assessments.
Performance Management: Duties form the basis for KPIs and evaluations.
Job Evaluation: JDs provide inputs for grading.
Training: Competency gaps inform IDPs and WEP integration.

HR3.4.7 JD Creation & Approval
Manager drafts JD based on functional needs.
HR reviews for completeness and alignment.
Senior Management approves final version.
JD may undergo job evaluation.

HR3.4.8 JD Review Cycles
JDs are reviewed at least every two years or when roles or organisational needs change significantly.

HR3.4.9 Flexibility Clause
Due to the dynamic consulting environment, duties may vary within reasonable limits while respecting role grade and job boundaries.

HR3.4.10 Responsibilities
Managers: Draft and update JDs.
HR: Provide templates and review submissions.
Management: Approve JDs.
Employees: Review and acknowledge JDs.
SOP–HR3.4A: Job Description Development & Review Procedure
Initiate JD development based on new roles or changes.
Manager drafts JD.
HR reviews for quality and structure.
Consult stakeholders as needed.
Management approves JD.
Conduct job evaluation if required.
Issue JD to employee and document acceptance.
Review JD periodically or when changes occur.
HR3.5 – Succession Planning Policy
HR3.5.1 Policy Statement
TopSkills is committed to ensuring continuity and organisational resilience by identifying and developing internal talent to fill key roles. Succession planning applies across all functions and integrates with workforce planning, leadership development and Work Experience Programme (WEP) talent streams. The process covers not only senior leadership positions but also specialised roles whose loss would significantly disrupt operations or client delivery.

HR3.5.2 Purpose
The purpose of this policy is to provide a structured approach to:

Identify critical roles within TopSkills.
Assess internal talent and potential successors for those roles.
Develop employees so they are ready to assume greater responsibilities.
Integrate WEP-based talent into medium- and long-term succession pipelines.
Reduce risks associated with turnover, growth and organisational change.
HR3.5.3 Scope
This policy applies to all employees of TopSkills (permanent, fixed-term, project-based and trial contracts) and to high-potential WEP graduates who have transitioned or are likely to transition into employment. It does not apply to independent contractors unless explicitly identified for a future internal role.

HR3.5.4 Definitions
Succession Planning: A proactive, systematic process of identifying and developing individuals to fill key roles in the organisation.
Critical Role: A role whose vacancy would significantly impact operations, client service, revenue, compliance or organisational knowledge.
Successor: An employee identified as potential replacement for a critical role, categorised as ready now, ready soon or developing.
Leadership Pipeline: A progression path for employees to move into higher responsibility over time.
9-Box Talent Grid: A matrix used to segment talent based on performance and potential.
HR3.5.5 Identification of Critical Roles
Critical roles may include:

Strategic leadership roles and key managers.
Client-facing consultants and project leads.
HR, job evaluation, salary survey and performance management specialists.
Data analysts, systems and digital operations roles.
Finance and compliance roles.
WEP coordinators, mentors and training leads.
A role is considered critical if it is difficult to replace quickly, is essential to core services, holds unique institutional knowledge or has significant impact on client satisfaction, reputation or revenue.

HR3.5.6 Succession Planning Framework
The succession planning framework follows the steps below:

Identify Critical Roles: HR works with senior management to maintain a register of key roles.
Assess Talent: Use performance data, competency assessments, WEP transcripts and manager feedback to evaluate employees.
Segment Talent Using the 9-Box Grid: Place employees in the performance–potential matrix to identify development priorities.
Identify Successor Readiness: Classify successors as ready now, ready soon (1–2 years) or developing (2–4 years).
Develop Individual Succession Plans: Define development actions, training, WEP leadership tasks and exposure required.
Review & Update: Revisit talent placements and successors at least annually.
Talent Segmentation – 9-Box Grid
The 9-Box Grid is used to segment employees based on their sustained performance and their potential for greater responsibility. This helps target development and succession actions appropriately.

High PotentialMedium PotentialLow Potential
High PerformanceFuture Leaders
Ready Now / Ready Soon
Strong candidates for succession; suitable for leading projects and WEP cohorts.Core Players
Stable Growth
Reliable performers; may step into supervisory roles with targeted development.Depth Specialists
Technical Experts
High performance in a focused area; vital for quality and knowledge depth.
Medium PerformanceEmerging Talent
High Growth Path
Often includes strong WEP graduates; needs structured development and exposure.Effective Team Members
Steady, reliable contributors; benefit from skill strengthening.Inconsistent Talent
Needs Coaching
Performance is variable; requires close supervision, feedback and development support.
Low PerformanceMisaligned but High Potential
Role/Skill Mismatch
May be in the wrong role or lacking support; consider repositioning and targeted training.Underperforming Staff
Requires clear performance improvement plans and close follow-up.Critical Risk
Immediate Action Required
Persistent low performance and low potential; may require reassignment or exit.
Note: Placement in the 9-Box Grid is based on a combination of performance results, potential indicators, behaviour, demonstration of TopSkills values, WEP transcript data (where applicable), learning agility and leadership behaviours. The grid is a decision-support tool and does not replace professional judgement.

HR3.5.7 Development Strategies for Successors
Based on 9-Box placement and succession priorities, TopSkills may use the following strategies:

Stretch Assignments: Leading sub-projects, proposals, internal improvements or client-facing tasks.
Acting Appointments: Temporary assumption of a higher role during absences.
Job Rotation: Cross-functional exposure (e.g. job evaluation, salary surveys, recruitment, performance management, policy development, data analysis).
Coaching & Mentorship: One-to-one guidance from senior staff or project leads.
Formal Training: Internal and external courses, certifications and leadership programmes.
WEP Leadership Involvement: Supervising WEP cohorts, reviewing tasks and facilitating sessions to build leadership, coaching and delegation skills.
HR3.5.8 Monitoring & Review
Succession plans and talent segmentation are reviewed at least annually. HR, together with senior management, updates:

Critical role listings.
Successor readiness levels.
Development progress and outcomes.
Integration of new WEP graduates or staff into the pipeline.
HR3.5.9 Confidentiality & Transparency
Succession planning discussions are confidential and maintained by HR and senior management. Being identified as a potential successor does not guarantee promotion or appointment. However, employees may be made aware of development opportunities and expectations aligned to future roles.

HR3.5.10 Responsibilities
HR: Coordinate succession planning processes, maintain talent data, facilitate 9-Box reviews and track development progress.
Line Managers: Identify high-potential staff, provide accurate performance feedback and offer meaningful development opportunities.
Senior Management: Approve critical roles, succession plans and resource allocation for development.
Employees: Take ownership of their development, engage with learning opportunities and demonstrate readiness through performance and behaviour.
SOP–HR3.5A: Succession Planning Procedure
Identify Critical Roles: HR and management update the critical roles register annually.
Gather Talent Data: HR compiles performance results, WEP transcripts (where applicable), competency assessments and manager feedback.
Conduct Talent Review Meetings: HR and management place employees on the 9-Box Grid and identify potential successors with readiness levels.
Develop Successor Action Plans: Define development priorities, training, mentorship, WEP leadership tasks and stretch assignments for each successor.
Obtain Approvals: Senior management reviews and approves the consolidated succession plan.
Implement Development Actions: Managers assign agreed tasks, rotations and learning opportunities to successors.
Monitor Progress: HR and managers review development progress quarterly and adjust plans as needed.
Annual Review: Succession plans and 9-Box placements are refreshed each year in line with performance cycles and organisational changes.

Chapter 4: Employee Behaviour & Ethics

Chapter 4 – Employee Behaviour & Ethics
This chapter sets out the standards of behaviour, ethics and workplace conduct expected of all TopSkills employees. It promotes a respectful, safe and professional environment for staff, clients, Work Experience Programme (WEP) participants and other stakeholders. The policies below should be read together with the disciplinary, grievance, harassment, equality, conflict of interest, whistleblower and confidentiality policies in this chapter.

HR4.1 – Code of Conduct & Workplace Behaviour Policy
HR4.1.1 Policy Statement
TopSkills expects all employees to uphold high standards of professional and ethical behaviour. Employees must act with integrity, honesty, respect and accountability in all interactions and comply with applicable laws, regulations and organisational policies. Breaches of this Code may result in corrective action or formal disciplinary proceedings as outlined in HR4.3 – Disciplinary Procedures.

HR4.1.2 Purpose
This policy defines expected standards of conduct and ethics, promotes a safe and inclusive working environment, protects the reputation and assets of TopSkills and its clients and provides a reference for managing conduct concerns.

HR4.1.3 Scope
This policy applies to all employees of TopSkills, including permanent, fixed-term, project-based and short-term contracts. It also applies to interns, trainees and WEP participants when acting in an official TopSkills capacity. Independent contractors are expected to meet equivalent behavioural standards as set out in their agreements.

HR4.1.4 General Principles of Conduct
Integrity & Honesty: Be truthful, honour commitments and avoid misrepresentation.
Respect & Professionalism: Treat all persons with dignity, courtesy and fairness.
Confidentiality & Data Protection: Safeguard sensitive information and use it only for authorised purposes.
Compliance: Follow laws, regulations, client requirements and internal policies.
Safety & Wellbeing: Contribute to a safe, harassment-free work environment.
Professional Boundaries: Maintain appropriate boundaries with clients, colleagues and WEP participants.
Responsible Use of Time & Resources: Use organisational time and assets primarily for work-related purposes.
HR4.1.5 Expected Workplace Behaviours
Report to work punctually and reliably; communicate absences or delays promptly.
Follow reasonable instructions from supervisors and raise concerns respectfully.
Communicate clearly and courteously in meetings, emails and digital platforms.
Dress appropriately for the work setting and client expectations.
Handle client documents, data and internal tools carefully and confidentially.
Give and receive feedback in a constructive and professional manner.
HR4.1.6 Unacceptable Behaviour
The following behaviours are not acceptable and may lead to disciplinary action:

Harassment, bullying, intimidation or humiliation.
Discrimination on any unlawful ground.
Sexual harassment in any form.
Physical violence or threats of violence.
Fraud, theft, misappropriation or unauthorised use of assets.
Serious negligence or reckless disregard for procedures.
Unauthorised disclosure of confidential information.
Undeclared or unmanaged conflicts of interest.
Substance abuse at work or reporting to work under the influence.
Persistent lateness, absenteeism or abandonment of duties.
Misuse of digital platforms or social media in a way that harms TopSkills or clients.
HR4.1.7 Use of Organisation Assets & Systems
Use IT equipment, email, internet and other systems primarily for work-related purposes.
Refrain from accessing or distributing offensive or unlawful content.
Protect system access credentials and follow IT security guidelines.
HR4.1.8 Social Media & Public Representation
Employees must not present personal opinions as official TopSkills views without authorisation. Public comments about clients, colleagues or internal matters should be made only through approved channels. Social media content that may harm the reputation of TopSkills or its clients is prohibited.

HR4.1.9 Reporting Misconduct & Protection from Retaliation
Employees are encouraged to report suspected misconduct or policy breaches to their manager, HR or through designated whistleblowing channels. TopSkills prohibits retaliation against individuals who raise concerns in good faith or participate in investigations.

HR4.1.10 Responsibilities
Employees: Read, understand and comply with this Code; seek clarification when in doubt; report violations.
Line Managers: Model appropriate behaviour, address minor behaviour issues early and escalate serious matters.
HR: Provide guidance, maintain procedures and support fair application of the Code.
Management: Lead by example and ensure consistent application across the organisation.
SOP–HR4.1A: Managing Workplace Behaviour & Minor Conduct Issues
Identify Concern: Manager observes behaviour inconsistent with the Code.
Informal Discussion: Manager meets the employee privately, explains the concern and listens to their perspective.
Clarify Expectations: Manager reminds the employee of expected behaviours and agrees on specific improvements.
Support & Guidance: Manager may offer coaching, mentoring or re-orientation on relevant policies.
Follow-Up: Manager reviews behaviour after an agreed period and notes the outcome.
Escalation: If behaviour does not improve or if the misconduct is serious, the matter is referred to HR and handled under HR4.3 – Disciplinary Procedures.
HR4.2 – Grievance Handling Policy
HR4.2.1 Policy Statement
TopSkills is committed to a fair, respectful and supportive workplace. Employees have the right to raise concerns or complaints without fear of retaliation. The organisation will address grievances promptly, impartially and confidentially, resolving issues at the lowest effective level whenever possible.

HR4.2.2 Purpose
This policy provides a structured approach for raising and resolving grievances, ensures fair and timely handling of concerns and promotes open communication and workplace justice.

HR4.2.3 Scope
This policy applies to all employees, interns and trainees. WEP participants may also use this process when grievances relate to work assigned within TopSkills or external institutions under supervision.

HR4.2.4 What Constitutes a Grievance?
Workload concerns or unfair allocation of duties.
Unfair treatment, discrimination or harassment.
Unsafe working conditions or inappropriate behaviour.
Concerns relating to performance evaluations or feedback.
Breach of policy, procedure or employment contract.
Conflicts with colleagues or supervisors.
Concerns about pay, benefits or terms of engagement (after clarification with HR/Payroll).
Misuse of authority or inappropriate managerial conduct.
Any matter affecting dignity, wellbeing or ability to perform one’s role.
HR4.2.5 Principles of Grievance Handling
Confidentiality: Information shared only with those involved in resolving the grievance.
No Retaliation: Employees are protected from victimisation for raising concerns in good faith.
Timeliness: Grievances addressed promptly at all stages.
Fairness: Cases handled objectively and impartially.
Right to Be Heard: All parties may present their views.
Documentation: Formal grievances recorded securely by HR.
Right to Representation: Employees may request a colleague or approved representative.
Clear Escalation: Multi-level process for unresolved grievances.
HR4.2.6 Levels of Grievance Resolution
1. Informal Resolution (First Step)
The employee raises the concern with their supervisor or HR. Most issues can be resolved through discussion, clarification or adjustments.

2. Formal Grievance
If unresolved informally, the employee submits a written grievance to HR. HR acknowledges receipt, investigates and provides a written outcome.

3. Appeal
If dissatisfied with the outcome, the employee may appeal to a senior leader. The appeal decision is final.

HR4.2.7 Grievances Involving Serious Misconduct
Complaints involving serious misconduct (e.g. harassment, discrimination, unethical conduct) are immediately escalated to HR and handled according to relevant policies including HR4.3, HR4.4, HR4.5 and HR4.8.

HR4.2.8 Protection from Victimisation
Retaliation against any person who raises a grievance or participates in an investigation is strictly prohibited and may result in disciplinary action.

HR4.2.9 Responsibilities
Employees: Raise concerns promptly and truthfully; participate constructively.
Managers: Address issues sensitively and promptly; uphold confidentiality; prevent retaliation.
HR: Manage formal grievances, ensure fairness and maintain records.
SOP–HR4.2A: Grievance Handling Procedure
Identify Concern: Employee recognises a workplace issue causing dissatisfaction.
Informal Discussion: Employee raises the issue with the supervisor or HR for early resolution.
Formal Grievance: If unresolved, the employee submits a written grievance; HR acknowledges within 3 days.
Investigation: HR conducts interviews, reviews evidence and consults relevant parties.
Outcome: HR issues a written report outlining findings and recommended actions.
Implementation: Actions may include mediation, coaching, adjustments or disciplinary action.
Appeal: Employee may appeal within 7 days; senior leader reviews and decides.
Closure: HR documents and securely stores records of the grievance.
SOP–HR4.2B: Handling Sensitive, Anonymous or Third-Party Grievances
Receipt of Grievance: HR receives a sensitive, anonymous or third-party complaint via email, written report, call or designated channel and logs it with a unique reference number.
Initial Risk Assessment: HR assesses seriousness, potential harm, power imbalances and any immediate safety or reputational risks. Urgent matters are escalated to senior management.
Determine Investigation Approach: If sufficient information is available, HR proceeds with discreet fact-finding even if the complainant is anonymous. If details are insufficient, HR seeks clarification where possible or records the concern for monitoring.
Discreet Fact-Finding: HR interviews relevant parties and reviews available evidence, sharing only necessary information and preserving confidentiality as far as practicable.
Interim Protective Measures: Where appropriate, TopSkills may adjust reporting lines, work arrangements or access rights, or consider precautionary suspension in serious cases, in line with HR4.3 and applicable law.
Outcome & Actions: HR and management determine whether the grievance is substantiated and agree on corrective, developmental or disciplinary actions, as well as any process improvements needed.
Communication: Where possible, HR communicates to the complainant or reporting party that the matter has been reviewed and that appropriate steps are being taken, without breaching confidentiality of others.
Protection from Retaliation: HR monitors for any signs of victimisation and treats retaliation as separate misconduct subject to disciplinary action.
Documentation & Learning: HR keeps secure records of the grievance, steps taken and outcomes, and periodically reviews trends to strengthen prevention and training.
HR4.3 – Disciplinary Procedures
HR4.3.1 Policy Statement
TopSkills is committed to maintaining a professional and ethical workplace. When behaviour or performance falls below required standards, the organisation will address such matters fairly, consistently and in accordance with labour laws, internal policies and principles of natural justice. The disciplinary process is corrective rather than punitive.

HR4.3.2 Purpose
This policy outlines procedures for managing misconduct, gross misconduct and repeated behavioural issues, while protecting the rights of employees and safeguarding organisational standards.

HR4.3.3 Scope
This policy applies to all employees, interns and trainees. WEP participants are also covered when acting in a work capacity. Contractors are subject to contractual terms, although misconduct affecting clients or employees may result in termination.

HR4.3.4 Categories of Misconduct
Misconduct (Correctable Behaviour)
Repeated lateness or poor time management.
Failure to follow instructions or minor insubordination.
Inappropriate tone or unprofessional communication.
Negligence without serious harm.
Minor policy breaches.
Misuse of company time or minor misuse of resources.
Minor confidentiality lapses.
Gross Misconduct (May Justify Summary Dismissal)
Fraud, theft or misappropriation.
Serious dishonesty or falsification of documents.
Harassment, bullying or sexual harassment.
Physical violence or threats.
Serious breach of confidentiality or data security.
Cyber misuse or unauthorised system access.
Gross negligence causing harm or reputational damage.
Conduct resulting in loss of clients or legal exposure.
Criminal conduct affecting ability to perform duties.
HR4.3.5 Principles of Fair Disciplinary Action
Right to Information: Employee must receive written allegations.
Right to Be Heard: Employee must be given opportunity to respond.
Right to Representation: Employee may be accompanied by a colleague or approved representative.
Timeliness: Matters addressed promptly.
Consistency: Similar cases handled similarly.
Impartiality: No conflict of interest in decision-making.
Documentation: All disciplinary steps are documented.
HR4.3.6 Disciplinary Actions
For Misconduct
Verbal Warning (documented)
First Written Warning
Final Written Warning
Suspension with pay (for investigation)
Demotion or reassignment (where corrective)
For Gross Misconduct
Summary dismissal (after hearing)
Suspension pending hearing
Termination with notice (where mitigation exists)
HR4.3.7 Precautionary Suspension
Suspension is used to enable a fair investigation and is not a punishment. Suspension is normally with pay. A written notice stating the allegations, reason for suspension and expected conduct during suspension will be issued.

HR4.3.8 Investigation Prior to Hearing
HR conducts interviews and reviews evidence before any disciplinary hearing. No disciplinary action may be taken before investigation is completed.

HR4.3.9 Disciplinary Hearing Process
Notice: Employee receives written notice of hearing, allegations and evidence.
Hearing: HR facilitates hearing; manager presents case; employee responds; witnesses may be heard.
Decision: Based on evidence, consistency and mitigating factors.
Outcome: Employee receives written outcome and right of appeal.
HR4.3.10 Appeals
Employee may appeal within 7 days on grounds of procedural unfairness, new evidence or unreasonable penalty. A senior manager uninvolved in the original hearing will review the case.

HR4.3.11 Special Considerations for WEP Participants
WEP participants may receive corrective coaching instead of formal sanctions. Serious misconduct or repeated violations may result in removal from the programme or other action.

HR4.3.12 Responsibilities
Managers: Identify misconduct early and ensure fairness.
HR: Lead investigations, guide process and maintain records.
Employees: Cooperate honestly and uphold standards.
SOP–HR4.3A: Procedure for Handling Misconduct
Identify misconduct.
Initial review by manager and HR.
Conduct informal investigation.
Issue written notice of intended action.
Hold disciplinary hearing.
Document findings and decision.
Issue corrective action (warning or other measure).
Monitor behaviour and support improvement.
SOP–HR4.3B: Procedure for Handling Gross Misconduct
Receive allegation or report.
Conduct immediate risk assessment.
Place employee on precautionary suspension (if necessary).
Conduct formal investigation.
Issue notice of disciplinary hearing with evidence.
Hold disciplinary hearing.
Decide on appropriate sanction (including potential summary dismissal).
Provide appeal option.
Document and close the case.
HR4.4 – Harassment & Sexual Harassment Policy
HR4.4.1 Policy Statement
TopSkills is committed to providing a safe, respectful and inclusive working environment free from harassment, bullying, intimidation and sexual harassment. The organisation has zero tolerance for any behaviour that demeans, threatens or violates the dignity of employees, clients, WEP participants or other stakeholders.

HR4.4.2 Purpose
This policy defines harassment and sexual harassment, outlines reporting procedures, protects complainants from retaliation and promotes a workplace culture of dignity and professionalism.

HR4.4.3 Scope
This policy applies to all employees, interns, trainees, WEP participants, consultants and contractors, as well as interactions with clients and client staff when representing TopSkills.

HR4.4.4 Definitions
A. Harassment
Harassment is any unwelcome conduct, whether verbal, physical, non-verbal or digital, that violates a person’s dignity or creates an intimidating, hostile or offensive environment.

Verbal: insults, mockery, threats, offensive jokes.
Non-verbal: hostile gestures, exclusion, displaying offensive materials.
Digital: harassing messages, inappropriate emails or online behaviour.
Physical: intimidation, blocking movement or unwanted physical proximity.
B. Sexual Harassment
Sexual harassment is any unwelcome sexual advance, request for sexual favour or conduct of a sexual nature, including verbal, non-verbal, digital or physical actions.

Verbal: sexual jokes, comments or requests for sexual favours.
Non-verbal: leering, suggestive gestures or display of explicit material.
Digital: sending inappropriate images or messages.
Physical: unwanted touching, grabbing or attempted sexual assault.
HR4.4.5 Zero Tolerance Areas
Sexual harassment of any form.
Harassment involving threats or intimidation.
Harassment of WEP participants.
Harassment by supervisors toward subordinates.
Retaliation against complainants or witnesses.
HR4.4.6 Reporting Harassment
Employees may report harassment to their supervisor, HR, any senior manager, anonymously or via client HR where applicable. All reports will be investigated promptly and confidentially.

HR4.4.7 Protection from Retaliation
Retaliation against anyone who reports a concern or participates in an investigation is strictly prohibited and may result in disciplinary action.

HR4.4.8 Confidentiality
The identity of complainants will be protected as far as possible. Information is shared only on a need-to-know basis and records are kept securely.

HR4.4.9 Interim Measures
HR may implement temporary measures such as separating parties, adjusting reporting arrangements or precautionary suspension to ensure safety and a fair investigation.

HR4.4.10 Investigation Process
Interviewing complainant.
Interviewing respondent.
Interviewing witnesses.
Reviewing evidence (messages, emails, etc.).
Preparing a written investigation report.
HR4.4.11 Outcomes
No case to answer.
Coaching or corrective action.
Warnings (written or final).
Removal from supervisory duties.
Reassignment or review of responsibilities.
Summary dismissal for severe misconduct.
Termination of WEP participation if applicable.
HR4.4.12 Support to Complainants
TopSkills will provide support, ensure no disadvantage arises from reporting and conduct follow-up checks to prevent retaliation or recurrence.

HR4.4.13 Responsibilities
Employees: Treat others with respect and report concerns promptly.
Managers: Prevent harassment, address concerns and protect complainants.
HR: Lead investigations, maintain confidentiality and ensure fairness.
SOP–HR4.4A: Handling Harassment & Sexual Harassment Complaints
Report Received: Complaint may be verbal, written, anonymous or through a third party.
Safety & Risk Assessment: HR assesses immediate risks and implements temporary protection measures.
Acknowledge Complaint: HR explains process and timelines.
Investigation: Interviews, evidence review and documentation.
Findings & Recommendations: HR prepares report with appropriate action.
Outcome Communication: Complainant and respondent are informed separately.
Appeal Option: Respondent may appeal under HR4.3.
Post-Case Monitoring: HR monitors workplace to prevent retaliation and recurrence.
HR4.5 – Equal Employment, Diversity & Non-Discrimination Policy
HR4.5.1 Policy Statement
TopSkills is an equal opportunity employer. All employment-related decisions are based on merit, competence, performance and organisational needs, and not on unlawful discrimination. The organisation values diversity and strives to create an inclusive environment for employees, interns, Work Experience Programme (WEP) participants, contractors and applicants.

HR4.5.2 Purpose
This policy promotes equality of opportunity, prohibits discrimination and bias, and guides managers and employees in making fair and objective decisions across the employment life cycle.

HR4.5.3 Scope
The policy applies to recruitment, onboarding, training, deployment, promotion, remuneration and exit for all employees, interns, trainees and WEP participants. It also informs the engagement of consultants and contractors as far as reasonably practicable.

HR4.5.4 Key Principles
Equal Opportunity: All suitably qualified individuals have an equal chance to compete for roles and development opportunities.
Non-Discrimination: Decisions are not based on gender, age, disability, race, religion, health status or other protected characteristics.
Merit & Fairness: Selection and promotion are based on role-related criteria, performance and potential.
Inclusion & Dignity: Everyone is treated with respect and included in the workplace community.
Reasonable Accommodation: Practical adjustments are considered for individuals with disabilities or health conditions.
Transparency & Accountability: Significant decisions are justifiable and documented.
HR4.5.5 Application Areas
Recruitment & Selection
Job adverts use inclusive, gender-neutral language.
Shortlisting is based on objective, job-related criteria.
Interviewers avoid intrusive or discriminatory questions.
Training & Development
Access to training and WEP opportunities is based on development needs and potential.
High-value opportunities are distributed using transparent criteria.
Promotion & Career Progression
Promotion decisions are based on performance, competencies and readiness, not protected characteristics.
Pay & Benefits
Pay structures are guided by job evaluation and market data, not discriminatory practices.
Work Assignments & Opportunities
Key assignments are allocated fairly, avoiding discriminatory patterns.
Exit & Termination
Termination or non-renewal decisions are based on lawful and objective reasons.
HR4.5.6 Reasonable Accommodation
TopSkills will consider reasonable adjustments to working hours, methods, tools or locations to enable individuals with disabilities or health-related needs to perform their roles and participate fully in work and programme activities, subject to operational feasibility.

HR4.5.7 Prohibited Practices
Refusing to hire or promote someone based on a protected characteristic.
Using intrusive or discriminatory interview questions.
Unequal pay for equal value work without objective justification.
Systematically excluding individuals from training or assignments due to bias or stereotypes.
Retaliating against someone for raising a discrimination concern.
HR4.5.8 Raising Concerns About Discrimination
Individuals who believe they have experienced discrimination may raise the matter informally with a manager or HR, or lodge a formal grievance under HR4.2. Where the discrimination involves harassment, HR4.4 also applies.

HR4.5.9 Responsibilities
Employees: Treat others fairly, avoid discriminatory conduct and report concerns.
Managers: Make objective, documented decisions; challenge discriminatory behaviour and support reasonable accommodation.
HR: Provide guidance, training, monitoring and oversight of equality-related practices.
SOP–HR4.5A: Equal Opportunity in Recruitment & Promotion
Role Definition: Ensure job descriptions and adverts focus on essential skills and competencies.
Advertising: Use inclusive language and diverse channels where possible.
Shortlisting: Apply a standard scoring matrix based on agreed criteria; involve more than one reviewer for critical roles when feasible.
Interviews: Ask structured, job-related questions and avoid discriminatory or intrusive questions.
Promotion Decisions: Base decisions on performance data, competencies, readiness and organisational needs; provide feedback to internal candidates.
Documentation: Retain adverts, shortlisting records, interview notes and decision rationale for audit and transparency.
SOP–HR4.5B: Reasonable Accommodation & Adjustments
Request/Identification: Employee or applicant discloses a need, or manager/HR identifies a potential need and opens a confidential discussion.
Assessment: HR and manager consider the nature of the limitation, job requirements and potential adjustments.
Decision: Agree on practical adjustments (e.g. flexible hours, modified tasks, assistive tools) where feasible.
Implementation: Document and implement adjustments, with a review date.
Monitoring: Periodically review whether adjustments remain effective and make changes as needed.
HR4.5 – Equal Employment, Diversity & Non-Discrimination Policy
HR4.5.1 Policy Statement
TopSkills is an equal opportunity employer committed to promoting diversity, fairness and inclusion in all aspects of work. Employment-related decisions are based on merit, competence, performance and organisational needs. No employee, intern, Work Experience Programme (WEP) participant, contractor or job applicant shall be discriminated against on the basis of gender, pregnancy, marital status, age, disability, race, colour, ethnic or social origin, language, religion, belief, culture, health status, HIV status, nationality or any other status protected by law.

HR4.5.2 Purpose
This policy promotes equality of opportunity, prohibits discrimination and bias, and guides managers and employees in making fair, objective and transparent decisions throughout the employment and talent development life cycle.

HR4.5.3 Scope
This policy applies to all stages of the employment cycle: recruitment, onboarding, deployment, training, performance management, promotion, remuneration and exit. It covers all employees, interns, trainees, WEP participants, consultants and contractors where applicable.

HR4.5.4 Key Principles
Equal Opportunity: All suitably qualified individuals receive fair consideration for jobs and development opportunities.
Non-Discrimination: Decisions shall not be influenced by gender, disability, race, religion or any other protected status.
Merit & Fairness: Recruitment, promotion and rewards are based on objective, job-related criteria.
Inclusion & Dignity: Everyone is treated with respect and has the right to participate fully in the workplace.
Reasonable Accommodation: Practical adjustments are made for individuals with disabilities or health-related needs where feasible.
Transparency & Accountability: Significant decisions are documented and defensible.
HR4.5.5 Application Areas
Recruitment & Selection
Job adverts use inclusive, gender-neutral language.
Shortlisting is based strictly on skills, competencies and experience.
Interviewers avoid biased, intrusive or discriminatory questions.
Diverse candidate pools and decision-making groups are encouraged where practical.
Training & Development
Training and WEP opportunities are allocated based on development needs and potential.
Access to high-value opportunities is based on transparent criteria.
Promotion & Career Progression
Promotion decisions rely on performance, competencies, readiness and organisational needs.
Bias or assumptions shall not influence career decisions.
Pay & Benefits
Salary structures and adjustments are based on job evaluation, market benchmarks and organisational principles.
Employees performing work of equal value shall receive equitable pay.
Work Assignments & Opportunities
Key projects and assignments are allocated fairly and not based on stereotypes or discriminatory assumptions.
WEP tasks and learning opportunities are rotated equitably.
Exit & Termination
Exit decisions must be lawful, objective and free of discriminatory influence.
Documentation must demonstrate legitimate organisational reasons.
HR4.5.6 Reasonable Accommodation
TopSkills will provide reasonable adjustments to support employees or applicants with disabilities or health conditions. Adjustments may include modified duties, flexible work arrangements, assistive tools or other accommodations depending on operational feasibility and individual needs.

HR4.5.7 Prohibited Practices
Refusing to hire or promote someone due to gender, disability, age, race, religion or other protected characteristics.
Using intrusive or discriminatory interview questions.
Offering unequal pay for equal value work without objective justification.
Excluding individuals from training or assignments because of bias or stereotypes.
Retaliating against anyone who reports discrimination or participates in an investigation.
HR4.5.8 Reporting Concerns
Anyone who believes they have experienced discrimination may report the matter informally to their manager or HR, or lodge a formal grievance under HR4.2. Concerns involving harassment may also be addressed through HR4.4.

HR4.5.9 Responsibilities
Employees: Treat others fairly, avoid discriminatory behaviour and report concerns.
Managers: Ensure decisions are fair, objective and documented; address discriminatory actions.
HR: Provide training, monitor patterns, support investigations and ensure compliance.
SOP–HR4.5A: Equal Opportunity in Recruitment & Promotion
Role Definition: Ensure job descriptions and adverts focus on essential skills and requirements.
Advertising: Use inclusive language and diverse recruitment channels.
Shortlisting: Apply objective scoring matrices; involve more than one reviewer when feasible.
Interviews: Use structured questions; avoid discriminatory or intrusive inquiries.
Promotion Decisions: Rely on performance data, competencies, readiness and organisational needs.
Documentation: Maintain records of shortlists, interview notes and decision rationale for transparency.
SOP–HR4.5B: Reasonable Accommodation & Adjustments
Request/Identification: An employee or applicant requests support, or HR identifies a potential need.
Confidential Discussion: HR and the individual discuss the limitation and potential adjustments.
Assessment: Evaluate feasibility, cost and operational impact of adjustments.
Decision & Implementation: Agree on practical adjustments and document the arrangement.
Monitoring: Review periodically to ensure adjustments remain appropriate.
HR4.6 – Conflict of Interest Policy
HR4.6.1 Policy Statement
TopSkills requires all employees, consultants and Work Experience Programme (WEP) participants to act in the best interests of the organisation and its clients at all times. Any actual, potential or perceived conflict between personal interests and organisational duties must be declared and appropriately managed or avoided.

HR4.6.2 Purpose
This policy defines conflicts of interest, outlines common risk situations and provides procedures for declaring and managing such conflicts in order to protect TopSkills, its clients and its people from undue influence, bias and reputational harm.

HR4.6.3 Scope
The policy applies to all employees, interns, trainees, WEP participants, consultants and contractors and covers activities involving clients, vendors, recruitment, procurement, performance evaluations and allocation of work or opportunities.

HR4.6.4 Definitions
A conflict of interest arises when personal, financial or other interests may interfere with, or appear to interfere with, an individual’s ability to act in the best interests of TopSkills or its clients.

Actual conflict: A current conflict between personal interests and official duties.
Potential conflict: A situation that could develop into a conflict in future.
Perceived conflict: A situation that may appear to others as a conflict, even if no improper action has occurred.
HR4.6.5 General Principles
Transparency: Conflicts must be declared promptly.
Objectivity: Decisions should not be influenced by personal interests.
No Personal Gain: Positions at TopSkills must not be used for unauthorised personal benefit.
Duty to Update: Declarations must be updated if circumstances change.
HR4.6.6 Common Conflict Situations
Personal Relationships: Supervising or making employment decisions about close family members, romantic partners or close friends.
External Employment & Side Businesses: Running or working in businesses that compete with, or draw on confidential information from, TopSkills or its clients.
Financial Interests: Holding shares or financial stakes in clients, vendors or competitors where one can influence related decisions.
Vendors & Procurement: Recommending or approving vendors where the employee or close family members have an interest.
WEP & Mentorship: Allocating WEP tasks or opportunities in a way that favours individuals with undisclosed personal ties.
HR4.6.7 Gifts, Hospitality & Favours
Modest and reasonable hospitality linked to legitimate business activities may be acceptable. However, gifts, favours or hospitality that could influence, or appear to influence, decision-making must be refused or discussed with HR for guidance. Cash gifts or cash equivalents should not be accepted.

HR4.6.8 Declaration & Management of Conflicts
Employees must declare actual, potential or perceived conflicts of interest as soon as they become aware of them, using a conflict of interest declaration form or by notifying HR in writing. Until guidance is provided, they should refrain from making or influencing decisions related to the conflict.

HR and management may respond by:

Allowing the activity with conditions or additional oversight.
Reassigning decision-making responsibilities.
Restricting involvement in particular projects or processes.
Requiring the employee to cease the conflicting activity.
HR4.6.9 Breach of Policy
Failure to declare or appropriately manage conflicts of interest may result in corrective action or disciplinary measures in line with HR4.3 – Disciplinary Procedures. Where client interests are affected, additional contractual or reputational consequences may arise.

HR4.6.10 Responsibilities
Employees: Identify and declare conflicts, seek guidance and avoid compromised decisions.
Managers: Model ethical behaviour, review disclosures and implement management plans.
HR: Maintain a register of declarations, provide guidance and integrate this policy into induction and training.
Senior Management: Ensure high-risk areas have appropriate checks and oversight.
SOP–HR4.6A: Conflict of Interest Declaration & Review
Identification: Employee recognises a potential or actual conflict (e.g. relationship, financial interest, side business).
Declaration: Employee submits a conflict of interest declaration or written notice to HR.
Acknowledgement: HR acknowledges receipt and logs the declaration in a confidential register.
Assessment: HR and the relevant manager evaluate the level of risk and type of conflict.
Decision & Management Plan: Appropriate measures are agreed (e.g. oversight, reassignment, restriction or cessation of activity).
Communication: HR informs the employee of the decision and expectations in writing.
Review: Ongoing or long-term conflicts are reviewed periodically or when circumstances change.
SOP–HR4.6B: Gifts, Hospitality & Favours
Offer Received: Employee receives a gift, favour or hospitality offer from a client, vendor, candidate or other party.
Initial Assessment: Employee considers the value, timing and context of the offer.
Decision: Modest, clearly non-influencing offers may be accepted; significant or sensitive offers should be declined or referred to HR for guidance.
Recording: Where appropriate, HR records significant offers and accepted items in a gifts and hospitality register.
Follow-Up: Where an offer is accepted under special circumstances, restrictions may be placed on the employee’s involvement in related decisions.
HR4.7 – Confidentiality, Data Protection & Whistleblowing Policy
HR4.7.1 Policy Statement
TopSkills handles sensitive information about employees, Work Experience Programme (WEP) participants, clients, candidates, contractors and other stakeholders. The organisation is committed to protecting this information, ensuring it is used only for legitimate business purposes and kept secure at all times.

TopSkills also encourages staff and participants to raise concerns about suspected wrongdoing, malpractice or breaches of policy. Individuals who make such disclosures in good faith are protected from retaliation.

HR4.7.2 Purpose
This policy:

Sets out confidentiality and data protection obligations for everyone working with TopSkills.
Defines how personal and organisational data must be collected, used, stored and shared.
Provides a safe channel (whistleblowing) for reporting serious concerns or violations.
Protects those who make disclosures in good faith from victimisation.
HR4.7.3 Scope
This policy applies to all employees, interns, trainees, WEP participants, consultants and contractors, and covers:

HR records and personnel files.
Client and project information.
Candidate applications, CVs and assessment results.
WEP data, mentorship records and transcripts.
Financial, contractual and operational information.
Any other information classified as confidential by TopSkills or its clients.
HR4.7.4 Confidentiality Obligations
All individuals covered by this policy must:

Use confidential information only for authorised business purposes.
Not disclose confidential information to unauthorised persons inside or outside the organisation.
Protect information from loss, unauthorised access or misuse.
Continue to observe confidentiality even after leaving TopSkills or completing a WEP or consultancy engagement.
HR4.7.5 Data Protection Principles
When handling personal data, TopSkills commits to:

Lawfulness & Fairness: Collect data for legitimate, clearly defined purposes.
Purpose Limitation: Use data only for the purposes for which it was collected, or for related purposes that are compatible.
Data Minimisation: Collect only the data necessary for the task.
Accuracy: Keep data accurate and up to date where reasonable.
Storage Limitation: Keep data only as long as needed for business, legal or contractual reasons.
Security: Protect data against unauthorised access, loss, destruction or damage.
Confidentiality: Share personal data only on a need-to-know basis.
HR4.7.6 Handling & Storage of Information
Files (physical or digital) must be stored securely and not left unattended in accessible areas.
Electronic records should be protected by passwords and, where appropriate, encryption.
Access to systems and folders is granted on a role-based need-to-know basis.
Portable devices (laptops, phones, flash drives) must be handled with care and secured against theft or loss.
HR4.7.7 Data Sharing with Clients & Third Parties
Personal and confidential data may be shared with clients or third parties only when:

There is a legitimate business need or contractual obligation.
Sharing is limited to what is necessary for the purpose.
Reasonable measures are taken to ensure the recipient also protects the data.
HR4.7.8 Breaches of Confidentiality or Data Protection
A data breach includes loss, unauthorised access, disclosure, alteration or destruction of confidential or personal data. All suspected breaches must be reported immediately to HR or the designated data protection contact. Breaches may result in disciplinary action under HR4.3 and may also have legal or contractual consequences.

HR4.7.9 Whistleblowing – Protected Disclosures
Whistleblowing is the reporting of genuine concerns about suspected wrongdoing or risk, including but not limited to:

Fraud, theft or corruption.
Serious breach of confidentiality or data protection.
Harassment, abuse, exploitation or serious misconduct.
Unsafe practices or serious health and safety risks.
Unethical behaviour or serious violation of company policies.
Attempts to conceal any of the above.
HR4.7.10 Reporting Channels
Concerns may be reported through:

A direct manager or supervisor (where appropriate).
HR, in person, by email or other agreed channels.
A designated senior manager for sensitive matters.
Any approved anonymous or confidential reporting mechanism, if available.
Reports should be made in good faith and provide as much detail as possible (dates, people involved, nature of concern, any supporting evidence).

HR4.7.11 Protection from Retaliation
TopSkills prohibits retaliation against anyone who:

Makes a whistleblowing disclosure in good faith.
Participates in an investigation.
Supports another person who has raised a concern.
Retaliation may include dismissal, demotion, intimidation, isolation, harassment or other negative treatment and will be treated as misconduct or gross misconduct under HR4.3.

HR4.7.12 Investigation of Disclosures
All credible reports will be assessed promptly. Depending on the nature of the disclosure:

HR and/or senior management will appoint an investigator or investigation team.
Relevant evidence will be collected and reviewed.
Findings will be documented and appropriate actions recommended.
Where lawful and appropriate, the whistleblower will be informed that the matter has been addressed, although detailed outcomes may remain confidential.

HR4.7.13 Responsibilities
Employees, WEP Participants & Contractors: Safeguard confidential information, follow data protection practices and report suspected wrongdoing.
Managers: Model confidentiality, ensure secure handling of information and respond to reports in a timely, fair and confidential manner.
HR: Maintain relevant procedures, oversee investigations, ensure records are secure and provide training and guidance.
SOP–HR4.7A: Responding to Confidentiality & Data Protection Breaches
Identify & Report: Any person who becomes aware of a suspected or actual breach reports it immediately to HR or the designated data protection contact.
Contain: Take immediate steps (where possible) to prevent further loss or access (e.g. revoke access, change passwords, recover devices).
Assess: HR and relevant managers assess the nature, scope and impact of the breach.
Investigate: Collect facts, review systems or processes involved and identify root causes.
Remedial Action: Implement corrective and preventive measures (e.g. system changes, training, policy updates).
Disciplinary Process: If negligence or misconduct is found, manage under HR4.3 – Disciplinary Procedures.
Documentation: Record the breach, response actions and lessons learned in a secure log.
SOP–HR4.7B: Handling Whistleblowing Reports
Receipt: HR or the designated officer receives a report (verbal, written or anonymous) and records key details.
Initial Assessment: Assess seriousness, potential risks and whether immediate protective action is needed.
Acknowledgement: Where the whistleblower is known, acknowledge receipt and outline next steps.
Investigation: Appoint an impartial investigator or team; gather evidence; interview relevant parties; maintain confidentiality.
Findings & Recommendations: Document findings and propose appropriate corrective or disciplinary action.
Outcome Communication: Inform relevant decision-makers and, where appropriate, update the whistleblower that the concern has been addressed.
Protection from Retaliation: Monitor for signs of victimisation and take action if any retaliation occurs.
Closure & Learning: Close the case, record it in a secure register and identify lessons to strengthen controls and culture.
HR4.8 – Workplace Conduct, Digital Ethics & Client Interaction Standards
HR4.8.1 Policy Statement
TopSkills expects all employees, consultants, interns and Work Experience Programme (WEP) participants to uphold high standards of professional behaviour, digital responsibility, integrity and respect in all environments, especially when interacting with clients. Unprofessional behaviour may expose the organisation to reputational or contractual risk and will be addressed in line with HR4.3 – Disciplinary Procedures.

HR4.8.2 Purpose
This policy defines workplace conduct standards, digital ethics rules and expectations for client interaction, and provides a framework for handling misconduct and protecting TopSkills’ reputation.

HR4.8.3 Scope
Applies to all employees, consultants, interns, trainees and WEP participants representing TopSkills internally or externally.

HR4.8.4 General Behavioural Expectations
Show respect, courtesy and professionalism at all times.
Be punctual, reliable and responsive.
Maintain professional boundaries and avoid gossip or disrespectful behaviour.
Preserve confidentiality and avoid casual discussion of sensitive matters.
Represent TopSkills positively in all engagements.
HR4.8.5 Client Interaction Standards
Follow client protocols, IT rules and instructions.
Communicate clearly and respectfully.
Maintain confidentiality of all client information.
Avoid asking for favours, loans or personal assistance from clients.
Escalate concerns internally within TopSkills, not directly to the client.
HR4.8.6 Digital Conduct & Online Behaviour
Avoid sharing screenshots, emails or client data without authorisation.
Maintain professionalism in WhatsApp, Slack, Teams and email.
Avoid posting work-related information or client images on social media.
Use digital tools responsibly and for authorised purposes only.
HR4.8.7 Use of Social Media
Do not disclose client information online.
Do not present personal opinions as TopSkills positions.
Maintain respectful and professional online behaviour.
HR4.8.8 Professional Boundaries
Avoid inappropriate relationships or communications.
Do not use work-related relationships for personal gain.
Stay within defined mentorship or supervisory roles.
HR4.8.9 Behaviour in Virtual Workspaces
Join meetings from appropriate environments.
Keep camera on in client meetings unless agreed otherwise.
Mute when not speaking and avoid background distractions.
HR4.8.10 Prohibited Behaviour
Harassment, bullying or abusive conduct.
Confidentiality breaches or misuse of digital tools.
Chronic lateness, absenteeism or failure to communicate.
Dishonesty or misrepresentation of work.
Inappropriate messaging or social media activity.
HR4.8.11 WEP Participant Conduct
Maintain professionalism as learners-in-training.
Record time and output accurately.
Respect client boundaries and workplace norms.
HR4.8.12 Reporting Misconduct
Concerns may be raised via supervisors, HR, WEP mentors or whistleblowing channels under HR4.7. All cases are reviewed fairly and confidentially.

HR4.8.13 Enforcement
Violations may result in counselling, warnings, removal from client sites, suspension from WEP or disciplinary action under HR4.3.

SOP–HR4.8A: Managing Conduct Concerns
Identification: Concern raised internally or by a client.
Initial Review: Supervisor/HR assesses risk.
Fact-Finding: Collect statements, messages and evidence.
Assessment: Categorise the concern (minor, serious, boundary or digital breach).
Action: Coaching, warning or escalation to HR4.3.
Documentation: Record decisions confidentially.
SOP–HR4.8B: Digital Behaviour & Social Media Conduct
Identify the Issue: Screenshot sharing, inappropriate online conduct or misuse of systems.
Contain: Remove inappropriate content and adjust access if needed.
Review: HR assesses logs, context and severity.
Classification: Negligence, misconduct, confidentiality breach or reputational risk.
Corrective Action: Training, warnings or formal disciplinary action.
Controls: Strengthen digital communication practices and reinforce confidentiality rules.

Chapter 5: Compensation & Benefits

Chapter 6: Separation & Exit

Chapter 7: Programmes, Work Modes & Safety

Chapter 8: HR Administration & Operational Standards