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Privacy Policy

1. GENERAL

1.1 Tenet Group Ltd together with any group companies (“we” “us” “our”) are committed to protecting and respecting your privacy. We are the data controller and will process your personal data in accordance with the Data Protection Act 2018, Regulation (EU) 2016/679 (the “GDPR”) and the Privacy and Electronic Communications (EC Directive) Regulations 2003  as amended from time to time as well as any national laws which relate to the processing of personal data (“data protection legislation”).

1.2 Please read the following carefully to understand our views and practices regarding Your Data and how we will treat it.
This policy applies to information we collect about:

  • Visitors to our websites (including corporate TenetSelect, TenetConnect, TenetLime and Consumer websites);
  • Members;
  • Customers;
  • Tenet Compliance Services clients and their consumer clients; and
  • Organisations that support our advisor development programmes Suppliers.

2. VISITORS TO OUR WEBSITES

2.1 We may collect and process personal data about you in the following circumstances:

2.1.1 when you complete the online contact forms on our websites (“Sites”) providing us with your name, address, email address and contact number.
2.1.2 whenever you provide information to us when reporting a problem with our Sites, making a complaint, making an enquiry or contacting us for any other reason. If you contact us, we may keep a record of that correspondence;
2.1.3 when you visit our Sites we will retain details such as traffic data, location data, weblogs and other communication data, and the resources that you access (see section 2.2.2 on Cookies below); and
2.1.4 whenever you disclose your information to us, or we collect information from you in any other way, through our Sites.

2.2 We may also collect data in the following ways:

IP Address

2.2.1 We may collect information about your device, including where available your Internet Protocol address, for reasons of fraud protection. We may also collect information about your device’s operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

Cookies and Tracking

2.2.2 Use of cookies - A cookie is a small text file which is placed onto your computer (or other electronic device) when you access our website. We use cookies on this website to:

  • carry out research and statistical analysis to help improve our content, products and services and to help us better understand our customer requirements and interests; and
  • make your online experience more efficient and enjoyable.

2.2.3 Description of cookies - We may use the following categories of cookies on our website:

  • Strictly necessary: These are cookies which are essential for certain features of our website to work.These cookies do not record identifiable personal information and we do not need your consent to place these cookies on your device.Without these cookies we will be unable to provide all or part of our services to you.
  • Performance monitoring: We use these cookies to collect details on an anonymous basis about how you use our websites.This information may be used to help us improve our websites and understand how effective our adverts are. In some cases we use trusted third parties to collect this information for us but they only use the information for the purposes explained.
  • Functionality: These cookies are used to provide services or remember your settings. These cookies are aimed at enhancing your user experience by remembering your preferences. The information these cookies collect is anonymous and does not enable us to track your browsing activity on other websites.

The table below explains what cookies we use and why:

Cookie Name Purpose

Google Analytics

_ga

To collect details on an anonymous basis about how you use our websites

First Visit Pop-Up

homepage

To ask for your consent in order to use cookies on this website.

2.2.4 Consent - In most cases we will ask for your consent in order to use cookies on this website. Please note that we do not require your consent where the cookie is essential in order for us to provide you with a product or service you have requested.

2.2.5 How to turn off cookies - If you do not want to accept cookies, you can change your browser settings accordingly. If you do this, please be aware that you may lose some of the functionality of this website. For further information about cookies and how to disable them please go to the Information Commissioner’s webpage on cookies: https://ico.org.uk/for-the-public/online/cookies/.

Website Links

2.3 Our Site may, from time to time, contain links to and from the websites of third parties. Please note that if you follow a link to any of these websites, such websites will apply different terms to the collection and privacy of your personal data and we do not accept any responsibility or liability for these policies. Please check before you submit your information to these websites.

3. MEMBERS

3.1 We will collect details such as names, addresses, email addresses, contact numbers, financial information and employment references via the member application forms both online and in hard copy format. We may also receive details of credit checks undertaken where you have supplied these to us. Depending on the legal structure of the prospective member, such personal data may relate to a sole trader, directors, guarantors, shareholders, partners, registered advisers, arrangers and members of staff.

3.2 In order to comply with our legal obligations, we will:

3.2.1 use your personal data to undertake due diligence and ensure our members are fit and proper in accordance with the Financial Services and Markets Act 2000 (“FSMA”) and Financial Conduct Authority Handbook rules;
3.2.2 provide you with regulatory updates and information in accordance with FSMA requirements; and
3.2.3 pass your personal data to the Financial Conduct Authority in order to comply with our legal obligations and may also pass your personal data to the Financial Ombudsman Service and the Financial Services Compensation Scheme to assist with an investigation or complaint or other authorities required by law.

3.3 We will use personal data provided to comply with our contractual obligations arising from any agreements we enter into with members and share the data with our panel of financial institutions who can assist in the provision of financial services to customers. We will use the personal data for our legitimate interests including:

3.3.1 sharing personal data with organisations that support our advisor development programmes;
3.3.2 obtaining references using the contact details provided;
3.3.3 marketing our own products and services by mail and email; and
3.3.4 with your consent, sharing such data with third party financial institutions and our group companies for the purpose of marketing their financial services and products which may be of interest.

3.4 We will not transfer any member personal data outside the United Kingdom unless permitted to do so by data protection legislation (see section 12 of this Privacy Policy) and we will retain the data for as long as a member remains part of our network and for a period of 6 years from the termination of our agreement with a member. For unsuccessful applicants for membership, we will retain the personal data for up to 15 years in accordance with FCA guidance.

4. CUSTOMERS

4.1 Our members share customer personal data with us including name, address, telephone number, email address, health information and financial information. We are subject to a legal obligation to monitor member’s compliance with the FSMA and Financial Conduct Authority rules. This monitoring and any para-planning service we are instructed to undertake on behalf of a member will include the processing of customer personal data. We will also process customer personal data for our legitimate interests including:

4.1.1 to assist with staff and member training;
4.1.2 deal with complaints and defend claims;
4.1.3 to send customer satisfaction surveys; and
4.1.4 to facilitate the payment process to our members.

4.2 We will not transfer any personal data outside the United Kingdom unless permitted to do so by data protection legislation (see section 12 of this Privacy Policy) and we will retain customer personal data for 80 years.

5. TENET COMPLIANCE SERVICES CLIENT FIRMS AND THEIR CONSUMER CLIENTS

5.1 In relation to Tenet Compliance Services client firms, we will collect details such as names, addresses, email addresses, contact numbers, financial information via our Tenet Compliance Services client application form. We will use the personal data to comply with our contractual obligations and provide you with the compliance services you have requested.

5.1.1 We will use the personal data for our legitimate interests including:

5.1.1.1 sharing personal data with organisations that support our advisor development programmes;
5.1.1.2 marketing our own products and services by mail; and
5.1.1.3 with your consent, sharing such data with third party financial institutions and our group companies for the purpose of marketing their financial services and products which may be of interest.

5.2 As part of the compliance services provided to Tenet Compliance Services client firms we may process personal data relating to Tenet Compliance Services client’s consumers including name, address, telephone number, email address, health information and financial information. We will process such data to comply with our contractual obligations with Tenet Compliance Services client firms and in accordance with the Tenet Compliance Services’ instructions (including processing personal data as part of checks/review services we carry out for quality and compliance services).

5.3 Tenet Compliance Services client firms will ensure that they obtain their consumer’s consent to the processing of their personal data prior to sharing the data with us.

5.4 We will not transfer any personal data outside the United Kingdom unless permitted to do so by data protection legislation (see section 12 of this Privacy Policy) and we will retain Tenet Compliance Services client personal data for a period of 6 years from termination of our contract with a Tenet Compliance Services client. For Tenet Compliance Services client consumer personal data, we will retain the personal data for 6 years.

6. ORGANISATIONS THAT SUPPORT OUR ADVISOR DEVELOPMENT PROGRAMME

We collect information relating to the key contact of an organisation. This includes the individual’s name, email address and telephone number. This information is collected in order to supply the services requested from us, to comply with our contractual obligations and to provide notification of any changes to our services. We do not share the personal information collected with third parties and we will only retain the personal information for the term of the contract for services. We will not transfer any personal data outside the United Kingdom unless permitted to do so by data protection legislation (see section 12 of this Privacy Policy).

7. SUPPLIERS

We will collect details such as contact names, address, email address and telephone number in order to contact you about goods and/or services we have ordered from you, to comply with our contractual obligations and to place further orders. We may share your personal data with our employees to manage our relationship with you and we will keep your personal data for as long as we require your goods and/or services subject to a maximum of six years from the date of our last contact with you. We will not transfer your personal data outside the United Kingdom unless permitted to do so by data protection legislation (see section 12 of this Privacy Policy).

8. INTRODUCERS

8.1 We will collect details such as names, addresses, email addresses, contact numbers, financial information and employment references via the introducer application forms. We may also receive details of credit checks undertaken where you have supplied these to us. Depending on the legal structure of the prospective introducer such personal data may relate to a sole trader, directors, company secretaries, shareholders, and partners.

8.2 In order to comply with our legal obligations, we will:

8.2.1 use your personal data to ensure you are suitable to act as an introducer and we satisfy the requirements of the ‘Principles for Business’ in accordance with the Financial Services and Markets Act 2000 (“FSMA”) and Financial Conduct Authority Handbook rules;
8.2.2 pass your personal data to the Financial Conduct Authority in order to comply with our legal obligations and may also pass your personal data to the Financial Ombudsman Service and the Financial Services Compensation Scheme to assist with an investigation or complaint or other authorities required by law; and
8.2.3 use your personal data to facilitate the payment of commissions to you.

8.3 We may share your personal data with our employees to manage our relationship with you and we will keep your personal data for as long as you are an introducer to us subject to a maximum of six years from the date of our last contact with you. We will not transfer your personal data outside the United Kingdom.

9. MARKETING

9.1 This section provides information relating to marketing correspondence we may send to you and does not include the regulatory updates we are required to send to you in accordance with FSMA requirements (see section 3.2.2).

9.2 We may use member and Tenet Compliance Services client firm personal data to provide you with details about our goods, services, business updates and events which we think may be of interest.

9.3 We will only send you marketing correspondence where you have given us your consent to do so. We will ask whether you would like us to send you marketing messages when you tick the relevant boxes when you complete an application form for any of our products or services. 

9.4 Upon providing your consent, you can opt-out of receiving the information detailed in section 9.2 at any time. To opt-out of receiving such information you can
click the unsubscribe button contained in any such communication received, or email us at authorisations@tenetgroup.co.uk or call 0113 239 0011 providing us with your name and contact details. It may take up to 7 days for this to take place.

9.5 Where we have your consent, we may use your personal data to market the services and products of third party financial institutions. You have the right to opt-out of receiving such marketing information by contacting us using the contact details described above in section 9.2 or clicking the unsubscribe button contained in any such communication received.

9.6 Where you have subscribed to receive marketing correspondence from us we will keep your personal data for six years from when you subscribed to receiving marketing information from us or until you unsubscribe from receiving such correspondence from us (whichever is earlier).

10. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

10.1 In accordance with data protection legislation we are required to notify you of the legal basis upon which we process your personal data. We process your personal data for the following reasons:

10.1.1 for performance of a contract we enter into with you;
10.1.2 where necessary for compliance with a legal obligation we are subject to; and
10.1.3 for our legitimate interests (as described within this policy).

10.2 We will also process your personal data where we have obtained your explicit consent.

11. DISCLOSURE OF YOUR DATA TO THIRD PARTIES

11.1 In addition to the third parties mentioned previously in this policy, we may disclose your personal data to third parties for the following legitimate business purposes:

11.1.1 staff members in order to facilitate the provision of services to you;
11.1.2 to our affiliated entities to support internal administration;
11.1.3 IT software providers that host our website and store data on our behalf;
11.1.4 service providers who provide us with software solutions and platforms in order to carry out our business and provide services (including, without limitation, open banking services);
11.1.5 Professional service providers who assist us with any customer complaints and
11.1.6 to a prospective buyer of some or all of our business or assets, in which case personal data including Your Data will also be one of the transferred assets. The recipient of the information will be bound by confidentiality obligations.

11.2 We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, eg in relation to ISO accreditation and the audit of our accounts.

11.3 We may disclose your personal data to the police, regulatory bodies, legal advisors or similar third parties where we are under a legal duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our agreements; or to protect our rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

11.3 We will not sell or distribute your personal data to other organisations without your approval.

12. CROSS-BORDER DATA TRANSFERS

12.1 We share your personal data within the Tenet Group. This will involve transferring your data outside the United Kingdom in accordance with data protection legislation.

12.2 We share your personal data with external third parties in order to provide our services to you. Some of these third parties may transfer personal data outside the United Kingdom. We require such third parties to ensure that such transfers take place in accordance with data protection legislation.

12.3 Whenever we transfer your personal data out of the United Kingdom, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; or
  • Where we use providers based in the US, we may transfer data to them if they are registered as being part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

12.4 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the United Kingdom.

13. DATA SECURITY

13.1 Information you provide to us is shared on our secure servers. We have implemented appropriate physical, technical and organisational measures designed to secure your information against accidental loss and unauthorised access, use, alteration or disclosure. In addition, we limit access to personal data to those employees, agents, contractors and other third parties that have a legitimate business need for such access. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

13.2 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

13.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to our Site; any transmission is at your own risk. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

14. ACCESS TO, UPDATING, DELETING AND RESTRICTING USE OF YOUR DATA

14.1 It is important that the personal data we hold about you is accurate and current. Please keep us informed if the personal data we hold about you changes.

14.2 Data protection legislation gives you certain rights in relation to your personal data. You have the right to object to the processing of your personal data in certain circumstances and to withdraw your consent to the processing of your personal data where this has been provided.

14.3 You can also ask us to undertake the following:

14.3.1 update or amend your personal data if you feel this is inaccurate;
14.3.2 remove your personal data from our database entirely;
14.3.3 send you copies of your personal data in a commonly used format and transfer your information to another entity where you have supplied this to us, and we process this electronically with your consent or where necessary for the performance of a contract;
14.3.4 restrict the use of your personal data; and
14.3.5 provide you with access to information held about you and for this to be provided in an intelligible form.

14.4 We may request specific information from you to help us confirm your identity. Data protection legislation may allow or require us to refuse to provide you with access to some or all the personal data that we hold about you or to comply with any requests made in accordance with your rights referred to above. If we cannot provide you with access to your personal data, or process any other request we receive, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

14.5 Please send any requests relating to the above to our Privacy Officer at dataprotection@tenetgroup.co.uk specifying your name and the action you would like us to undertake. Note that in relation to requests to access personal data.

15. RIGHT TO WITHDRAW CONSENT

Where you have provided your consent to the collection, processing and transfer of your personal data, you may withdraw that consent at any time. This will not affect the lawfulness of data processing based on consent before it is withdrawn. To withdraw your consent please contact us at authorisations@tenetgroup.co.uk.

16. CHANGES TO OUR PRIVACY POLICY

We reserve the right to update this privacy policy at any time, and any changes we make to our privacy policy will be posted on this page. We will notify you if there are any changes to this policy that materially affect how we collect, store or process your personal data. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose. We may process your personal without your knowledge or consent where required by applicable law or regulation.

17. CONTACT US

We have appointed a Privacy Officer to oversee compliance with this privacy policy. If you have any questions, comments or requests regarding this policy or how we use your personal data please contact our Privacy Officer at dataprotection@tenetgroup.co.uk. This is in addition to your right to contact the Information Commissioners Office if you are unsatisfied with our response to any issues you raise at https://ico.org.uk/global/contact-us/.

Last updated: 22 June 2020.

Disclaimer

The information on this site is for general guidance only and is subject to UK regulation and legislation. It is therefore restricted to consumers based in the UK.

All information provided by Tenet Group Ltd on the web site, is made available to provide immediate access for the convenience of interested persons. While Tenet Group Ltd believes the information to be reliable, human or mechanical error remains a possibility. Therefore, we can not guarantee the accuracy, completeness, timeliness, or correct sequencing of the information.

Tenet Group Ltd nor any of the sources of the information shall be responsible for any errors or omissions, or for the use or results obtained from the use of this information. Other specific cautionary notices may be included on other web pages maintained by Tenet Group Ltd.

The downloadable files located in this web site are provided by Tenet Group Ltd "as is" and "without guarantee". All downloadable files have been checked by up-to-date, virus checking software before they are made available, but this is no guarantee that they are virus free. Tenet Group Ltd make no representations of any kind concerning the quality, safety or suitability of the material, either express or implied.

No part of Tenet Group Ltd’s site content may be reproduced in any way, or by any means, without the prior written permission of Tenet Group Ltd.

Modern Slavery Act 2015 (“MSA”)

Tenet Group Ltd and Subsidiaries (“Tenet”) Slavery and Human Trafficking Statement for the Financial Year ending 30 September 2019

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Tenet has taken, and is continuing to take, to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern Slavery encompasses slavery, servitude, human trafficking and forced labour. Tenet has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings, and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our Business

Tenet is a UK based company which operates a Financial Services Network through its subsidiary companies, TenetConnect Limited, TenetConnect Services Limited and TenetLime Limited, all of which are authorised and regulated by the Financial Conduct Authority.

Tenet authorises individuals and corporate bodies to act as its Appointed Representatives in accordance with the Financial Services and Markets Act 2000.

Tenet is a service business within the financial services sector, providing amongst other things compliance and back office support to its Appointed Representatives who are authorised by us to provide financial advice and recommend financial products to retail customers within the United Kingdom.

Our Supply Chains

Our supply chains include suppliers of IT, telephone and office equipment, hotel conference facilities, insurance brokerage, professional services from our lawyers, accountants and other advisers.

Our suppliers are predominantly from the United Kingdom, Europe and the United States of America. Following a review of our suppliers, we determined that we are in a low risk industry as are the vast majority of our suppliers; therefore we do not consider the risk of modern slavery within our supply chain to be a significant risk.

Due Diligence Processes for Modern Slavery and Human Trafficking

We have taken appropriate steps to help ensure that slavery or human trafficking is not taking place in our supply chains by reviewing existing business and supply chains and reviewing and revising our procurement processes to ensure that Modern Slavery does not exist.

Our procurement process includes steps to ensure that assurance is sought from relevant suppliers that they have anti-slavery and human trafficking policies in place and whether they are taking steps to prevent slavery and human trafficking in their respective business and supply chains. We will not support or engage suppliers where they/we are aware of slavery or human trafficking in such suppliers’ business or supply chains or where a supplier has failed to give us the requisite assurances.

Our Working Practices

We allow all individuals who work or provide services to us the right to freely choose employment and the right to associate freely with other individuals. We offer an environment which is free from harassment and unlawful discrimination.

We ensure that our working practices are in accordance with the Equality Act 2010 and all employment legislation. We do not engage in forced or involuntary labour and have a zero tolerance approach to the same, meaning we do not tolerate any of our suppliers engaging in such conduct.

This statement is made under section 54(1) of the Modern Slavery Act 2015 and constitutes Tenet’s slavery and human trafficking statement for the financial year ending 30th September 2019.

This statement has been approved by Tenet’s Board of Directors and will be reviewed annually.

Signed by
MS Signature

Mark Scanlon
Chief Executive Officer

Date: 30 January 2020

Tenet Group Ltd - Gender Pay Gap Report 2017

Tenet Group Ltd (the Tenet Group) is required by law to publish an annual gender pay gap report. This is its report for the snapshot date of 5th April 2017.

  • The mean gender pay gap for TGL is 28%.
  • The median gender pay gap for TGL is 32%.
  • The mean gender bonus gap for TGL is 11%.
  • The median gender bonus gap for TGL is 26%.
  • The proportion of male employees in TGL receiving a bonus is 87% and the proportion of female employees receiving a bonus is 85%.

Pay quartiles by gender

BAND MALES FEMALES DESCRIPTION
A 28% 72% Includes all employees whose standard hourly rate places them at or below the lower quartile
B 34% 66% Includes all employees whose standard hourly rate places them above the lower quartile but at or below the median
C 51% 49% Includes all employees whose standard hourly rate places them above the median but at or below the upper quartile
D 68% 32% Includes all employees whose standard hourly rate places them above the upper quartile

The figures set out above have been calculated using the standard methodologies used in the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017.

What are the underlying causes of the Tenet Group’s gender pay gap?

Under the law, men and women must receive equal pay for:

  • the same or broadly similar work;
  • work rated as equivalent under a job evaluation scheme; or
  • work of equal value.

The Tenet Group is committed to the principle of equal opportunities and equal treatment for all employees, regardless of sex, race, religion or belief, age, marriage or civil partnership, pregnancy/maternity, sexual orientation, gender reassignment or disability. It has a clear policy of paying employees equally for the same or equivalent work, regardless of their sex (or any other characteristic set out above).

Tenet Group is therefore confident that its gender pay gap does not stem from paying men and women differently for the same or equivalent work. Rather its gender pay gap is the result of the roles in which men and women work within the Company and the salaries that these roles attract.

Across the UK economy as a whole, men are more likely than women to be in senior roles, while women are more likely than men to be in front-line roles at the lower end of the organisation. In addition, men are more likely to be in technical and IT-related roles, which attract higher rates of pay than other roles at similar levels of seniority. Women are also more likely than men to have had breaks from work that have affected their career progression, for example to raise children. They are also more likely to work part time.

At Tenet Group we have four group Board Directors, three of whom are women. We are therefore bucking the trend in this regard compared to most organisations. We are therefore committed to reducing the gender pay gap over time, and are undertaking several initiatives currently to assist in this regard:

  • A Company-wide Talent Development Programme and a Management Development Programme with at least a 50:50 split of men and women to ensure the talented men and women at Tenet have equal opportunities to progress into the technical and leadership roles of the future.
  • An annual salary benchmarking exercise conducted by HR and the Board of Directors, to ensure salaries for roles are aligned across the individual departments.
  • A proactive approach to internal recruitment, with all vacancies being advertised internally, and a culture which encourages staff, both male and female, to seek out and apply for progression opportunities. 70% of our internal applicants are women.
  • A dedicated training budget available to all staff who wish to progress their learning and development, whether this be through the achievement of regulatory qualifications, or other professional qualifications such as AAT, CIMA and CIPD.
  • A revamped Appraisal Form and process which has a focus on career development and personal development, to ensure that every member of staff has the opportunity to discuss their career aspirations and opportunities to develop with their line manager each year.
  • A more flexible approach to work – if a role can be done from home, or on non-standard working hours, or a combination of home and office working, we will look to demonstrate flexibility in this regard wherever possible.

None of these initiatives will, of itself, remove the gender pay gap - and it may be several years before some have any impact at all. In the meantime, the Tenet Group is committed to reporting on an annual basis on what it is doing to reduce the gender pay gap and the progress that it is making.

I, Emily Blain, Head of HR & Central Services, confirm that the information in this statement is accurate.

Signed

EB Signature

Date: 5th April 2018

Tenet Group Ltd - Gender Pay Gap Report 2018

Tenet Group Ltd (the Tenet Group) is required by law to publish an annual gender pay gap report.

This is its report for the snapshot date of 5th April 2018.

  • The mean gender pay gap for TGL is 18.3%.
  • The median gender pay gap for TGL is 21.7%.
  • The mean gender bonus gap for TGL is 35.7%.
  • The median gender bonus gap for TGL is 26.6%.
  • The proportion of male employees in TGL receiving a bonus is 78.4% and the proportion of female employees receiving a bonus is 86.5%.

Pay quartiles by gender

BAND MALES FEMALES DESCRIPTION
A 32.3% 67.7% Includes all employees whose standard hourly rate places them at or below the lower quartile
B 42.2% 57.8% Includes all employees whose standard hourly rate places them above the lower quartile but at or below the median
C 58.5% 41.5% Includes all employees whose standard hourly rate places them above the median but at or below the upper quartile
D 60.9% 39.1% Includes all employees whose standard hourly rate places them above the upper quartile

The figures set out above have been calculated using the standard methodologies used in the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017.

What are the underlying causes of the Tenet Group’s gender pay gap?

Under the law, men and women must receive equal pay for:

  • the same or broadly similar work;
  • work rated as equivalent under a job evaluation scheme; or
  • work of equal value.

The Tenet Group is committed to the principle of equal opportunities and equal treatment for all employees, regardless of sex, race, religion or belief, age, marriage or civil partnership, pregnancy/maternity, sexual orientation, gender reassignment or disability. It has a clear policy of paying employees equally for the same or equivalent work, regardless of their sex (or any other characteristic set out above).

The Tenet Group is therefore confident that its gender pay gap does not stem from paying men and women differently for the same or equivalent work. Rather its gender pay gap is the result of the roles in which men and women work within the organisation and the salaries that these roles attract.

Across the UK economy as a whole, men are more likely than women to be in senior roles (especially very senior roles at the top of organisations), while women are more likely than men to be in front-line roles at the lower end of the organisation. In addition, men are more likely to be in technical and IT-related roles, which attract higher rates of pay than other roles at similar levels of seniority. Women are also more likely than men to have had breaks from work that have affected their career progression, for example to bring up children. They are also more likely to work part time, and many of the jobs that are available across the UK on a part-time basis are relatively low paid.

This pattern from the UK economy as a whole is reflected in the make-up of Tenet Group’s workforce. This can be seen above in the table depicting pay quartiles by gender. This shows Tenet Group’s workforce divided into four equal-sized groups based on hourly pay rates, with Band A including the lowest-paid 25% of employees (the lower quartile) and Band D covering the highest-paid 25% (the upper quartile). In order for there to be no gender pay gap, there would need to be an equal ratio of men to women in each Band. However, within Tenet Group, 67% of the employees in Band A are women and 32% men. The percentage of male employees increases throughout the remaining Bands, from 42% in Band B to 60% in D.

How does Tenet Group’s gender pay gap compare with that of other organisations?

The vast majority of organisations have a gender pay gap, and we are pleased to be able to say that Tenet Group’s gap compares favourably with that of other organisations, including those within our industry.

The mean gender pay gap for the whole economy (according to the October 2018 Office for National Statistics (ONS) Annual Survey of Hours and Earnings (ASHE) figures) is 17.0%, while in the financial services sector it is 33.4%. At 18.3%, Tenet Group’s mean gender pay gap is, therefore, slightly above the UK average, but significantly lower than that for our sector.

The median gender pay gap for the whole economy (according to the October 2018 ONS ASHE figures) is 17.9%, while in the financial services sector it is 35.7%. At 21.7%, Tenet Group’s median gender pay gap is, therefore, slightly higher than the UK average, but again significantly lower than that for our sector.

Comparison with other organisations

  Tenet Group 2018 ONS ASHE whole economy 2018 ONS ASHE financial services sector
Mean gender pay gap 18.3% 17.0% 33.4%
Median gender pay gap 21.7% 17.9% 35.7%

The mean gender bonus gap and the median gender bonus gap for Tenet Group are relatively large at 35.7% and 26.6%. However, when looked at in terms of cash amounts rather than percentage terms, the figures involved are comparatively small, at £2,889 and £1,856 respectively, reflecting our existing policy of not paying large bonuses to individual members of staff.

The proportion of women at Tenet Group who received a bonus in the 12 months up to 5 April 2018 was 86%, while for men this was 78%. This reflects the fact that everyone at Tenet is eligible to participate in one of the Company’s performance bonus schemes, and also reflects the fact that we have a higher proportion of women overall working at the Tenet Group.

What is Tenet Group doing to address its gender pay gap?

To date, the steps that Tenet Group has taken to promote gender diversity in all areas of its workforce include the following:

  • A Company-wide Talent Development Programme and a Management Development Programme to ensure the talented men and women at Tenet have equal opportunities to progress into the technical and leadership roles of the future.
  • An annual salary benchmarking exercise conducted by HR and the Board of Directors, to ensure salaries are aligned with market rates across the business.
  • A fair approach to recruitment, with all vacancies being advertised internally, and a culture which encourages staff, both male and female, to seek out and apply for progression opportunities. 59% of our successful internal applicants over the last 12 months were women, whereas 51% of our successful external appointments were female.
  • A dedicated training budget available to all staff who wish to progress their learning and development, whether this be through the achievement of regulatory qualifications, or other professional qualifications such as AAT, CIMA and CIPD.
  • A revamped Appraisal Form and process which has a focus on career development and personal development, to ensure that every member of staff has the opportunity to discuss their career aspirations and opportunities to develop with their line manager each year.
  • A more flexible approach to work – if a role can be done from home, or on non-standard working hours, or a combination of home and office working, we will look to demonstrate flexibility in this regard wherever possible.
  • Using structured interviews for recruitment and promotions ensuring we ask exactly the same questions of all candidates in a predetermined order and format using pre-specified, standardised criteria. This makes the responses comparable and reduces the impact of unconscious bias.
  • Using skills-based assessment tasks in recruitment. In addition to interviews, for some of our more senior roles, we ask candidates to perform standardised tasks at an assessment centre that mirror those they would be expected to perform in the role. We assess their performance on those tasks to assess their suitability for the role, ensuring a standard scoring criteria across candidates for fairness.
  • Demonstrating transparency around salary ranges for vacancies to ensure staff can see that we are paying fair market rates for our vacancies, and to encourage salary negotiation.
  • Increased transparency surrounding pay and reward processes through the introduction of performance related pay and bonus structures, and a 'transparent pay at Tenet' article, published on the Staff Intranet in 2018.

As a result of these activities, Tenet Group’s mean gender pay gap has reduced significantly from 28% in April 2017 to 18% in April 2018, whilst the median pay gap has reduced from 32% to 22% also in this time period. Tenet’s scores now compare very favourably with that of other organisations in the financial services sector.

However, with an Executive Board that is 75% female, this is absolutely not a subject about which Tenet Group is complacent, and it is committed to doing everything that it can to continue to reduce the gap. However, its scope to act is limited in some areas - it has, for example, no direct control over the subjects that individuals choose to study or the career choices that they make.

Any further initiatives launched throughout the year will be reported on the company intranet.

I, Emily Blain, Head of HR & Central Services, confirm that the information in this statement is accurate.

Signed

EB Signature

Date: 11th January 2018

Tenet Group Ltd - Gender Pay Gap Report 2019

Tenet Group Ltd (the Tenet Group) is required by law to publish an annual gender pay gap report.

This is its report for the snapshot date of 5th April 2019.

  • The mean gender pay gap for TGL is 19.5%.
  • The median gender pay gap for TGL is 28.1%.
  • The mean gender bonus gap for TGL is -5.0%.
  • The median gender bonus gap for TGL is -0.5%.
  • The proportion of male employees in TGL receiving a bonus is 81.1% and the proportion of female employees receiving a bonus is 82.2%.

Pay quartiles by gender

BAND MALES FEMALES DESCRIPTION
A 24.6% 75.4% Includes all employees whose standard hourly rate places them at or below the lower quartile
B 42.6% 57.4% Includes all employees whose standard hourly rate places them above the lower quartile but at or below the median
C 57.4% 42.6% Includes all employees whose standard hourly rate places them above the median but at or below the upper quartile
D 61.8% 38.2% Includes all employees whose standard hourly rate places them above the upper quartile

The figures set out above have been calculated using the standard methodologies used in the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017.

What are the underlying causes of the Tenet Group’s gender pay gap?

Under the law, men and women must receive equal pay for:

  • the same or broadly similar work;
  • work rated as equivalent under a job evaluation scheme; or
  • work of equal value.

The Tenet Group is committed to the principle of equal opportunities and equal treatment for all employees, regardless of sex, race, religion or belief, age, marriage or civil partnership, pregnancy/maternity, sexual orientation, gender reassignment or disability. It has a clear policy of paying employees equally for the same or equivalent work, regardless of their sex (or any other characteristic set out above).

The Tenet Group is therefore confident that its gender pay gap does not stem from paying men and women differently for the same or equivalent work. Rather its gender pay gap is the result of the roles in which men and women work within the organisation and the salaries that these roles attract.

Across the UK economy as a whole, men are more likely than women to be in senior roles (especially very senior roles at the top of organisations), while women are more likely than men to be in front-line roles at the lower end of the organisation. In addition, men are more likely to be in technical and IT-related roles, which attract higher rates of pay than other roles at similar levels of seniority. Women are also more likely than men to have had breaks from work that have affected their career progression, for example to bring up children. They are also more likely to work part time, and many of the jobs that are available across the UK on a part-time basis are relatively low paid.

This pattern from the UK economy as a whole is reflected in the make-up of Tenet Group’s workforce. This can be seen above in the table depicting pay quartiles by gender. This shows Tenet Group’s workforce divided into four equal-sized groups based on hourly pay rates, with Band A including the lowest-paid 25% of employees (the lower quartile) and Band D covering the highest-paid 25% (the upper quartile). In order for there to be no gender pay gap, there would need to be an equal ratio of men to women in each Band. However, within Tenet Group, 75% of the employees in Band A are women and 25% men. The percentage of male employees increases throughout the remaining Bands, from 43% in Band B to 62% in D.

How does Tenet Group’s gender pay gap compare with that of other organisations?

The vast majority of organisations have a gender pay gap, and we are pleased to be able to say that Tenet Group’s gap compares favourably with that of other organisations, including those within our industry.

The mean gender pay gap for the whole economy (according to the 2019 Office for National Statistics (ONS) Annual Survey of Hours and Earnings (ASHE) figures) is 16.2%, while in the financial services sector it is 32.7%. At 19.5%, Tenet Group’s mean gender pay gap is, therefore, slightly above the UK average, but significantly lower than that for our sector.

The median gender pay gap for the whole economy (according to the October 2018 ONS ASHE figures) is 17.3%, while in the financial services sector it is 33.7%. At 28.1%, Tenet Group’s median gender pay gap is, therefore, higher than the UK average, but again lower than that for our sector.

Comparison with other organisations

  Tenet Group 2019 ONS ASHE whole economy 2019 ONS ASHE financial services sector
Mean gender pay gap 19.5% 16.2% 32.7%
Median gender pay gap 28.1% 17.3% 33.7%

We have a negative mean gender bonus gap and median gender bonus gap at Tenet Group, which means women achieved a higher amount of bonus overall compared to men in the 12 months up to 5 April 2019.

The proportion of women at Tenet Group who received a bonus in the 12 months up to 5 April 2019 was 82.2%, while for men this was 81.1%. This reflects the fact that everyone at Tenet is eligible to participate in one of the Company’s performance bonus schemes, and also reflects the fact that we have a higher proportion of women overall working at the Tenet Group.

What is Tenet Group doing to address its gender pay gap?

To date, the steps that Tenet Group has taken to promote gender diversity in all areas of its workforce include the following:

  • A Company-wide Talent Development Programme and a Management Development Programme to ensure the talented men and women at Tenet have equal opportunities to progress into the technical and leadership roles of the future.
  • An annual salary benchmarking exercise conducted by HR and the Board of Directors, to ensure salaries are aligned with market rates across the business.
  • A fair approach to recruitment, with all vacancies being advertised internally, and an in-built culture which encourages staff, both male and female, to seek out and apply for progression opportunities.
  • A dedicated training budget available to all staff who wish to progress their learning and development, whether this be through the achievement of regulatory qualifications, or other professional qualifications such as AAT, CIMA and CIPD.
  • A revamped Appraisal Form and process which has a focus on career development and personal development, to ensure that every member of staff has the opportunity to discuss their career aspirations and opportunities to develop with their line manager each year.
  • A more flexible approach to work – if a role can be done from home, or on non-standard working hours, or a combination of home and office working, we will look to demonstrate flexibility in this regard wherever possible.
  • Using structured interviews for recruitment and promotions ensuring we ask the same questions of all candidates in a predetermined order and format using pre-specified, standardised criteria. This makes the responses comparable and reduces the impact of unconscious bias.
  • Using skills-based assessment tasks in recruitment. In addition to interviews, for some of our more senior roles, we ask candidates to perform standardised tasks at an assessment centre that mirror those they would be expected to perform in the role. We assess their performance on those tasks to assess their suitability for the role, ensuring a standard scoring criteria across candidates for fairness.
  • Demonstrating transparency around salary ranges for vacancies to ensure staff can see that we are paying fair market rates for our vacancies, and to encourage salary negotiation.
  • Increased transparency surrounding pay and reward processes through the introduction of performance related pay and bonus structures, and a ‘Transparent Pay at Tenet’ article, published on the Staff Intranet.

As a result of these activities, Tenet Group’s mean gender pay gap remains lower than at April 2017 (28%), but slightly increased from April 2018 (18%) to 19.5% in April 2020. The median pay gap reduced from 32% to 22% but has since increased slightly again to 28%. However Tenet’s scores continue to compare very favourably with that of other organisations in the financial services sector.

With an Executive Board that is 75% female, this is absolutely not a subject about which Tenet Group is complacent, and it is committed to doing everything that it can to continue to reduce the gap. However, its scope to act is limited in some areas - it has, for example, no direct control over the subjects that individuals choose to study or the career choices that they make.

Any further initiatives launched throughout the year will be reported on the company intranet.

I, Emily Blain, Head of HR & Central Services, confirm that the information in this statement is accurate.

Signed

EB Signature

Date: 28th February 2020

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