Legals
Website GDPR Privacy Policy - Ethical Employment Policy - Carbon Reduction Plan - EDI Policy - Website Terms & Conditions - Cookie Policy
Website GDPR privacy notice
1. INTRODUCTION
This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.nicolaharkercoaching.com.
By providing us with your data, you warrant to us that you are over 13 years of age.
Nicola Harker is the data controller and I am responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Contact Details
Our full details are:
Full name of legal entity: Nicola Harker trading as Nicola Harker Coaching Consultancy Ltd
Email address: support@nicolaharkercoaching.com
Registered Address: 12 Fore Street, Chudleigh, Newton Abbot, Devon, England, TQ13 0HX
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at support@nicolaharkercoaching.com.
2.WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process the following categories of personal data about you:
· Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defense of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
· Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
· User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
· Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
· Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
· We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
Sensitive Data
We need to collect the following sensitive data about you in order to deliver coaching services.
Health Information relevant to coaching.
We require your explicit consent for processing sensitive data, so when you submit your details, we will send you a further communication asking for you to confirm your consent to this processing.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at support@nicolaharkercoaching.com . In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision making or any type of automated profiling.
3.HOW WE COLLECT YOUR PERSONAL DATA
We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails).
We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.
We may also receive data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
4. MARKETING COMMUNICATIONS
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes, we will get your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at support@nicolaharkercoaching.com at any time.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.
5.DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
• Service providers who provide IT and cloud-based system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers
• Government bodies that require us to report processing activities.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
6.INTERNATIONAL TRANSFERS
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
• We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
• Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
• If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
7.DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
8.DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9.YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email us at support@nicolaharkercoaching.com
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
10.THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
11. COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see my cookie policy.
Ethical Employment Policy
1. Policy Statement
Nicola Harker Coaching Consultancy Ltd is committed to conducting all of its activities with integrity, fairness, and respect for every individual connected with the business and its supply chains. I believe that ethical employment goes beyond legal compliance — it reflects who we are and how we choose to operate in the world.
This policy sets out my commitment as sole director to fair, safe, and lawful working practices — both within this organisation and throughout the suppliers, contractors, and partners we work with. Although the business currently has no employees, establishing these principles now is an important statement of values and a sound foundation for future growth.
2. Scope
This policy applies to:
• Nicola Harker as sole director, and any future employees, workers, or volunteers engaged by the business
• Contractors, consultants, freelancers, coaches, and associates engaged to deliver work on behalf of the business
• Suppliers of goods and services and others in our supply chain, at all levels where we have reasonable visibility or influence
As sole director, I take personal responsibility for upholding this policy and for communicating its requirements to all relevant parties.
3. Our Core Commitments
3.1 Lawful and Voluntary Employment
I am committed to engaging workers only on a voluntary basis. Forced labour, bonded labour, trafficked labour, and any form of modern slavery are absolutely prohibited. I will take all reasonable steps to ensure these practices do not exist anywhere within my supply chain or professional network.
3.2 Child Labour
I will not engage any individual below the minimum school leaving age. Where young workers (aged under 18) are employed by any supplier or associate, their work must be safe, age-appropriate, lawful, and non-hazardous.
3.3 Fair Pay and Benefits
Any individuals I directly engage will be paid at least the applicable UK National Living Wage or National Minimum Wage. Where appropriate, I will aspire to pay the Real Living Wage as calculated by the Living Wage Foundation. Pay arrangements will be transparent, lawful, and confirmed in writing. I encourage the same standard across my supply chain.
3.4 Working Hours and Rest
I will comply with the Working Time Regulations 1998 and will not require workers to work excessive or unreasonable hours. Entitlements to rest periods, rest breaks, and annual leave will be respected for all individuals I engage directly.
3.5 Equality, Diversity, and Inclusion
Nicola Harker Coaching Consultancy Ltd is fully committed to equal opportunities and to creating an inclusive environment. Discrimination on the grounds of any protected characteristic as defined by the Equality Act 2010 — including age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, or sexual orientation — is unacceptable and will not be tolerated. This applies to how I engage contractors, make procurement decisions, and conduct my practice.
3.6 Dignity at Work
Every person I work with or engage has the right to be treated with dignity, courtesy, and respect. Bullying, harassment, and intimidation in any form are unacceptable. I take this responsibility seriously both in how I personally behave and in the standards I expect from those I work with.
3.7 Health, Safety, and Wellbeing
I am committed to maintaining safe working conditions and to complying with applicable health and safety law. Given the nature of my business, I pay particular attention to psychological safety and the wellbeing of those I work with — both clients and those engaged in delivering services. Suppliers and associates are expected to maintain appropriate standards in their own operations.
3.8 Freedom of Association
I respect the right of workers to join trade unions, to associate freely, and to engage in collective bargaining. I will not penalise any individual for exercising these rights.
3.9 Clear Terms of Engagement
Any individuals I directly engage will receive clear, written terms at the outset, setting out the nature of the engagement, remuneration, expectations, and key rights. I will not use arrangements designed to obscure or misrepresent the true nature of a working relationship.
4. Supply Chain Standards
I recognise that as a small business my supply chain is likely to be modest in scale, but this does not diminish my responsibility to act ethically in procurement. I expect all suppliers, contractors, coaches, associates, and partners engaged through this business to uphold standards consistent with this policy, including:
• Compliance with all applicable employment and labour laws in their jurisdiction
• No use of forced, bonded, trafficked, or child labour in any form
• Payment of at least the applicable minimum wage to their workers
• Safe, healthy, and lawful working conditions
• Respectful treatment of all workers and associates
• Willingness to engage openly if concerns about their practices are raised
I will consider ethical employment standards when selecting suppliers and contractors. Where serious concerns arise that are not adequately addressed, I will review and may terminate the relationship.
5. Modern Slavery and Human Trafficking
Nicola Harker Coaching Consultancy Ltd is committed to acting in accordance with the Modern Slavery Act 2015. I will take proportionate steps to ensure that modern slavery and human trafficking have no place in my business or supply chain.
My commitments in this area include:
• Conducting proportionate due diligence when engaging new suppliers or associates
• Including expectations regarding modern slavery in my terms of engagement where appropriate
• Remaining alert to the warning signs of modern slavery in professional contexts
• Taking prompt action — including referral to appropriate authorities — if modern slavery is identified or credibly suspected
If the business reaches the relevant annual turnover threshold, I will publish a Modern Slavery Statement in accordance with the Act.
6. Raising Concerns
I welcome concerns raised in good faith about ethical employment — whether relating to my own practices or those of suppliers or associates connected to this business. Anyone raising a concern will be treated with respect and will not suffer any detriment for doing so.
Concerns may be raised directly with me, Nicola Harker, as sole director. All concerns received will be acknowledged and investigated appropriately. Where a concern involves potential criminal conduct — including suspected modern slavery — I will consider referral to the relevant authorities, including the National Crime Agency’s Modern Slavery helpline (0800 0121 700).
7. Compliance and Consequences
Compliance with this policy is a condition of engagement with Nicola Harker Coaching Consultancy Ltd. Where a contractor, supplier, or associate is found to have seriously or persistently breached these standards, I may:
• Terminate or decline to renew the relevant contract or arrangement
• Remove the individual or organisation from future consideration
• Refer the matter to relevant regulatory or law enforcement bodies where appropriate
8. Policy Review
This policy will be reviewed annually, or sooner if there are changes in legislation, business structure, or best practice guidance. I, Nicola Harker as sole director, am responsible for keeping this policy current and ensuring it reflects both our obligations and our values.
This policy has been adopted by Nicola Harker, sole director of Nicola Harker Coaching Consultancy Ltd, and reflects a genuine personal and professional commitment to ethical employment.
Carbon Reduction Plan
Publication Date
January 2026
Review Date
January 2027
Prepared by
Nicola Harker - Director
Framework Reference
UK Government PPN 06/21 — Taking Account of Carbon Reduction Plans in the Procurement of Major Government Contracts
NHS Wales Decarbonisation Plan
1. About Nicola Harker Coaching Consultancy Ltd
Nicola Harker Coaching Consultancy Ltd is a small, owner-led professional services business providing executive and leadership coaching and training across the public and private sectors. The business is operated by two co-directors who work on a hybrid basis — delivering services remotely via digital platforms and in person at client sites across the UK.
By nature of its operating model, Nicola Harker Coaching Consultancy Ltd has a relatively modest direct carbon footprint. There are no company-owned premises, no heavy plant or equipment, and no manufacturing processes. The primary sources of carbon emissions arise from:
• Business travel to and from client sites (road and rail)
• Use of personal vehicles for business purposes
• Home office energy consumption (electricity and heating)
• Digital infrastructure (video conferencing, cloud storage, and business software)
• Purchased goods and services (printing, stationery, and professional subscriptions)
Nicola Harker Coaching Consultancy Ltd recognises that, as a service business, its greatest opportunity to drive broader environmental impact lies in its influence on clients and the professional development programmes it delivers. We are committed to embedding sustainability and responsible leadership into our coaching and training practice.
2. Net Zero Commitment
Formal Declaration — Net Zero by 2050
Nicola Harker Coaching Consultancy Ltd commits to achieving net zero greenhouse gas (GHG) emissions across its operations by 2050, in alignment with the UK Government's legally binding net zero target under the Climate Change Act 2008 (as amended in 2019).
We further commit to making meaningful, measurable progress in reducing our carbon footprint ahead of 2050, including setting interim targets consistent with a 1.5°C pathway as defined by the Science Based Targets initiative (SBTi).
This Carbon Reduction Plan sets out the measures we have in place, and will put in place, to achieve these commitments.
Nicola Harker Coaching Consultancy Ltd endorses the UK Government's Ten Point Plan for a Green Industrial Revolution and is committed to contributing to the broader national transition to net zero through its business operations and through the professional development support it provides to client organisations.
3. Baseline Emissions Footprint
3.1 Methodology
Nicola Harker Coaching Consultancy Ltd's emissions have been assessed in line with the Greenhouse Gas (GHG) Protocol Corporate Standard, which categorises emissions across three scopes:
• Scope 1 — Direct emissions from sources owned or controlled by the organisation (e.g. combustion of fuel in company-owned vehicles).
• Scope 2 — Indirect emissions from purchased electricity, heat, or steam consumed by the organisation.
• Scope 3 — All other indirect emissions that occur in the value chain, including business travel, home working, purchased goods and services, and supply chain.
As a micro-business with one home-based director and no owned premises or fleet vehicles, Nicola Harker Coaching Consultancy Ltd has no material Scope 1 emissions. The majority of the organisation's emissions fall under Scope 3. Home working energy use is treated as Scope 3 in line with GHG Protocol guidance for organisations without fixed premises.
3.2 Baseline Emissions Inventory
The baseline year is 2026/27. Nicola Harker Coaching Consultancy Ltd will refresh this inventory annually and publish updated figures in its annual Carbon Reduction Report.
A record of current and planned actions are available on request in the full report from support@nicolaharkercoaching.com
4. Current Environmental Measures
The following measures are currently in place across Nicola Harker Coaching Consultancy Ltd's operations to reduce environmental impact and carbon emissions:
4.1 Remote-First Working & Digital Delivery
• Nicola Harker Coaching Consultancy Ltd operates a remote-first working model by design. Both director and associates work from home as their primary base, significantly reducing commuting and office-related energy consumption.
• Coaching and training programmes are delivered via video conferencing platforms (including Microsoft Teams and Zoom) wherever client requirements and programme design permit, minimising the need for in-person travel.
• All internal business operations — including administration, finance, communications, and document management — are conducted digitally with no reliance on physical infrastructure.
4.2 Sustainable Business Travel
• Rail travel is the preferred mode of transport for all business journeys where it is practical and time-efficient, in recognition of its significantly lower carbon intensity compared to private car or air travel.
• Where car travel is necessary, journey planning is carried out in advance to minimise mileage and, where feasible, to consolidate visits to multiple client locations. Associate access to an EV, used wherever possible.
• Nicola Harker Coaching Consultancy Ltd is committed to transitioning to electric vehicles (EV) for business use. The Director will prioritise EV or hybrid vehicles for privately-owned cars used for business purposes upon their next vehicle replacement.
• Air travel for domestic business purposes is avoided wherever possible, and train used instead. International travel, which is currently minimal or nil, will be assessed against a carbon cost test before being approved.
4.3 Home Office Energy
• The director sources home energy from 100% renewable electricity tariffs and are supported to do so as part of the business's sustainability commitment.
• Energy efficiency measures in home offices are encouraged, including use of energy-efficient lighting (LED), heating controls and timers to minimise unnecessary energy use during working hours.
• Nicola Harker Coaching Consultancy Ltd will reimburse reasonable costs associated with energy efficiency improvements to home offices that are used for business purposes, such as draught-proofing, solar power, or smart heating controls.
4.4 Digital Sustainability
• Nicola Harker Coaching Consultancy Ltd gives preference to cloud service providers and software vendors that have made credible commitments to renewable energy use and net zero operations (including Microsoft and Google, whose data centres are backed by renewable energy procurement).
• Video calls are conducted with cameras off where appropriate to reduce data transmission and associated energy consumption. This doesn’t apply to coaching calls.
• File storage is managed efficiently; unnecessary data duplication and archiving of redundant files is avoided to reduce storage footprint. Data storage is monitored bimonthly to reduce unnecessary storage.
4.5 Paperless Operations
• Nicola Harker Coaching Consultancy Ltd operates on a paperless-by-default basis. All proposals, contracts, invoices, reports, and coaching materials are produced and shared digitally.
• Printing is avoided wherever possible. Where physical materials are required for client-facing purposes, these are produced on recycled or sustainably sourced paper (Envopap) and printed using energy-efficient devices.
• Electronic signatures are used for all contractual documents, eliminating the need for postal correspondence.
4.6 Sustainable Procurement
• Nicola Harker Coaching Consultancy Ltd applies a sustainable procurement approach to all goods and services purchased in connection with the business. Preference is given to suppliers with demonstrable environmental credentials.
• Stationery and consumable purchases are minimised and, where required, sourced from sustainable or recycled sources.
• Professional development and learning resources are sourced in digital format wherever available.
4.7 Carbon Offsetting
• For residual emissions that cannot currently be eliminated through operational changes — in particular, necessary car travel — Nicola Harker Coaching Consultancy Ltd uses a certified carbon offsetting scheme accredited to the Gold Standard or Verified Carbon Standard (VCS) to neutralise its impact.
• Nicola Harker Coaching Consultancy Ltd recognises that offsetting is a transitional measure and is committed to reducing its reliance on offsets over time as direct emission reductions are achieved.
• Nicola Harker Coaching Consultancy commits to moving to an electric vehicle for business use by 2030.
5. Carbon Reduction Targets & Milestones
Nicola Harker Coaching Consultancy Ltd has established the following targets and milestones in pursuit of net zero by 2050. These targets will be reviewed and updated annually in line with emerging guidance, the SBTi framework, and our own measured performance.
2026 — Renewable energy
Directors confirm they are on 100% renewable electricity tariffs for home offices used for business.
2030 — EV transition target
Director’s vehicle used for business to be electric or plug-in hybrid.
2030 — Interim net zero target
Achieve a minimum 50% reduction in total GHG emissions against the 2026/7 baseline, with remaining emissions offset via certified high-quality carbon credits.
2035 — Supply chain target
Ensure that all significant third-party suppliers and subcontractors engaged by Nicola Harker Coaching Consultancy Ltd have their own carbon reduction plans in place.
2040 — Deep decarbonisation target
Achieve a minimum 75% absolute reduction in total GHG emissions against the 2026 baseline.
2050 — Net Zero target
Achieve net zero GHG emissions across all scopes. Any residual unavoidable emissions to be neutralised through certified carbon removal credits (not offsets).
6. Embedding Carbon Reduction in Our Practice
Nicola Harker Coaching Consultancy Ltd recognises that, as leadership coaches and trainers, we have a unique opportunity and responsibility to support the leaders and organisations we work with to understand and act on the climate challenge. We embed this in our practice in the following ways:
• Responsible Leadership: Sustainability, climate literacy, and responsible decision-making are integrated as themes within our executive coaching and leadership development programmes where relevant to client context.
• Role Modelling: We are transparent with clients about our own carbon reduction commitments and measures, and model the behaviours we encourage in others.
• Client Collaboration: Where clients are on their own net zero journeys, we actively support them to embed sustainability into their leadership culture, team behaviours, and decision-making processes.
• Continuous Learning: The director commits to maintaining and developing their understanding of sustainability, climate science, and environmental governance to ensure our coaching and training remains current and evidence-based.
7. Governance & Accountability
7.1 Ownership
Responsibility for the delivery and oversight of this Carbon Reduction Plan rests with the Director of Nicola Harker Coaching Consultancy Ltd. Given the size of the organisation, no separate sustainability committee is required; however, carbon reduction is a standing agenda item for the co-directors' regular business reviews.
7.2 Monitoring & Measurement
• Business travel records (mileage, rail journeys, and costs) are tracked monthly by the director and used to calculate estimated Scope 3 travel emissions.
• Home office energy consumption is estimated annually using HMRC-approved flat rate calculations or, where smart meters are available, actual consumption data.
• Carbon offsetting purchases are recorded and retained as part of the business's financial records.
• An annual carbon review will be conducted each January to assess performance against targets, update the emissions inventory, and review the measures in this plan.
7.3 Reporting & Transparency
• This Carbon Reduction Plan will be published on Nicola Harker Coaching Consultancy Ltd's website and made available to clients and procurement bodies on request.
• An annual Carbon Reduction Report will be produced each year, summarising progress against targets, updated emissions data, and any new measures introduced.
• Nicola Harker Coaching Consultancy Ltd will report against this plan in response to any client or public sector procurement requirements, including those arising from PPN 06/21.
7.4 Review Cycle
This Carbon Reduction Plan will be formally reviewed and updated at least annually, and in response to any material change in the business's operating model, applicable legislation, or best practice guidance on net zero reporting.
8. Formal Declaration
Declaration by Nicola Harker Coaching Consultancy Ltd
I, the director of Nicola Harker Coaching Consultancy Ltd, confirm that:
1. This Carbon Reduction Plan sets out our genuine and current commitment to achieving net zero greenhouse gas emissions by 2050 in the United Kingdom.
2. The environmental measures described in this plan are in place or in active development and reflect the actual operating practices of our business.
3. We commit to measuring, monitoring, and reporting our carbon emissions annually, setting science-aligned interim targets, and continuously improving our performance against this plan.
4. We understand that this Carbon Reduction Plan may be relied upon by public sector clients and procurement bodies in accordance with the UK Government's Procurement Policy Note 06/21 and related guidance.
5. We will publish and maintain this plan on our company website and make it available on request.
9. References & Further Information
• HM Government — Net Zero Strategy: Build Back Greener (2021)
• HM Government — Procurement Policy Note 06/21: Taking Account of Carbon Reduction Plans in the Procurement of Major Government Contracts
• Greenhouse Gas Protocol — Corporate Accounting and Reporting Standard (revised edition)
• Science Based Targets initiative (SBTi) — Corporate Net-Zero Standard
• Climate Change Act 2008 (as amended 2019) — UK Net Zero Target
• Gold Standard Foundation — Carbon Offsetting Certification
• Verified Carbon Standard (VCS) — Verra Carbon Offsetting
EDI Policy
1. Introduction & Purpose
Nicola Harker Coaching Consultancy Ltd is committed to building an inclusive workplace where every individual is treated with dignity, respect, and fairness. We recognise that diversity in all its forms — including but not limited to age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation — strengthens our organisation and enables us to better serve our clients and communities.
This policy sets out Nicola Harker Coaching Consultancy Ltd's approach to equality, diversity, and inclusion (EDI) across all aspects of employment and professional life. It reflects our obligations under the Equality Act 2010 and demonstrates our wider commitment to a values-led, people-first culture.
This policy applies to all employees, contractors, agency workers, volunteers, and anyone acting on behalf of Nicola Harker Coaching Consultancy Ltd, regardless of seniority or contract type.
2. Protected Characteristics
Nicola Harker Coaching Consultancy Ltd will not tolerate discrimination, harassment, or victimisation in relation to any of the protected characteristics defined under the Equality Act 2010:
• Age
• Disability
• Gender reassignment
• Marriage and civil partnership
• Pregnancy and maternity
• Race (including colour, nationality, and ethnic or national origin)
• Religion or belief (including lack of belief)
• Sex
• Sexual orientation
We also extend our commitment to fairness to individuals based on socio-economic background, neurodivergence, and caring responsibilities, even where these are not covered as statutory protected characteristics.
3. Recruitment & Hiring
3.1 Commitment to Fair Recruitment
Nicola Harker Coaching Consultancy Ltd is committed to fair, transparent, and consistent recruitment practices that attract a diverse range of candidates and select on the basis of merit, skill, and potential.
3.2 Job Advertising
• All job adverts will use inclusive, bias-neutral language and will be reviewed prior to publication.
• Vacancies will be advertised across a range of channels to maximise reach to underrepresented groups.
• Person specifications will focus on demonstrable skills and behaviours, avoiding unnecessary requirements that could disadvantage protected groups.
• Nicola Harker Coaching Consultancy Ltd will indicate its commitment to EDI in all external job postings.
3.3 Selection Process
• Shortlisting and interviewing will be carried out by trained individuals using structured criteria applied consistently to all candidates.
• At least two people will be involved in all interview panels wherever practicable.
• Interview panels will be encouraged to be diverse in composition.
• All candidates will be assessed against the same criteria, and notes will be recorded and retained in line with our data retention policy.
• Nicola Harker Coaching Consultancy Ltd operates a Disability Confident approach and will guarantee an interview to any disabled candidate who meets the minimum criteria for a role.
3.4 Pre-Employment Checks
All pre-employment checks will be carried out consistently and without discrimination. Criminal record checks (where required) will comply with Rehabilitation of Offenders Act 1974 guidelines and will only consider convictions relevant to the role.
3.5 Positive Action
Where Nicola Harker Coaching Consultancy Ltd identifies that a particular group is underrepresented within the organisation or at a particular level, we may take proportionate positive action measures, such as targeted outreach or development programmes, in accordance with Section 158 of the Equality Act 2010.
4. Workplace Culture & Behaviour
4.1 Our Cultural Commitment
Nicola Harker Coaching Consultancy Ltd aspires to foster a culture of belonging where all employees feel valued, heard, and empowered to bring their authentic selves to work. Leaders at every level are accountable for modelling inclusive behaviours and setting the tone.
4.2 Prohibited Conduct
The following behaviours are strictly prohibited and will be treated as a disciplinary matter under the Company's Disciplinary Policy:
• Direct discrimination: treating someone less favourably because of a protected characteristic.
• Indirect discrimination: applying a practice or provision that puts individuals with a protected characteristic at a particular disadvantage.
• Harassment: unwanted conduct related to a protected characteristic that has the purpose or effect of violating dignity or creating an intimidating, hostile, degrading, humiliating, or offensive environment.
• Sexual harassment: any unwanted conduct of a sexual nature.
• Victimisation: treating someone less favourably because they have raised an EDI concern, made a complaint, or supported a colleague in doing so.
• Bullying: persistent, offensive, abusive, intimidating, or insulting behaviour that makes the recipient feel upset, threatened, humiliated, or vulnerable.
4.3 Inclusive Language & Communication
• All employees are expected to use respectful and inclusive language in person, in writing, and in digital communications.
• Employees are encouraged to speak up if they witness language or behaviour that falls short of these standards.
• Nicola Harker Coaching Consultancy Ltd will provide guidance and training on inclusive communication as part of its EDI programme.
4.4 Employee Networks & Inclusion Groups
Nicola Harker Coaching Consultancy Ltd supports and encourages the formation of employee-led networks and inclusion groups. These provide a forum for colleagues with shared experiences or interests to connect, share perspectives, and contribute to the development of our EDI strategy.
4.5 Training & Awareness
• All new employees will complete EDI awareness training as part of their onboarding.
• Annual refresher training will be provided to all employees.
• Managers will receive enhanced training covering unconscious bias, inclusive leadership, and how to handle EDI-related concerns.
• Training effectiveness will be reviewed periodically and updated to reflect best practice.
4.6 Raising Concerns
Employees who experience or witness discrimination, harassment, or other breaches of this policy are encouraged to report it. Reports can be made to a line manager, HR, or via the Company's confidential reporting mechanism. All reports will be handled sensitively, promptly, and fairly.
Employees can also raise concerns through the Company's Grievance Policy. Nicola Harker Coaching Consultancy Ltd will not tolerate any form of retaliation against an employee who raises a concern in good faith.
5. Accessibility & Reasonable Adjustments
5.1 Our Commitment to Accessibility
Nicola Harker Coaching Consultancy Ltd is committed to ensuring that its workplace, systems, and processes are accessible to all employees and job applicants. We recognise that disability and health conditions may affect people in different ways, and we take a proactive approach to removing barriers.
5.2 Reasonable Adjustments
In line with the Equality Act 2010, Nicola Harker Coaching Consultancy Ltd will make reasonable adjustments to remove or reduce disadvantage experienced by disabled employees or job applicants. This applies at all stages of the employment relationship, including:
• Recruitment and selection processes
• Induction and training
• Day-to-day working arrangements
• Performance management and appraisal
• Career development and promotion
• Redundancy and exit processes
Adjustments will be considered on an individual basis, taking into account the specific needs of the employee and the operational requirements of the business. Examples of adjustments may include, but are not limited to:
• Flexible or adjusted working hours
• Provision of assistive technology or specialist equipment
• Alternative formats for written materials
• Adjusted interview formats or additional time in assessments
• Phased return to work following illness or absence
• Reallocation of minor duties
5.3 Process for Requesting Adjustments
Employees who believe they may require a reasonable adjustment should discuss this with their line manager or HR at the earliest opportunity. The process is as follows:
• The employee (and/or their manager) raises a request with HR.
• HR will engage in an open, supportive dialogue with the employee to understand their needs.
• An occupational health referral may be arranged where appropriate.
• An agreed adjustment plan will be documented and communicated to relevant parties.
• Adjustments will be reviewed regularly and updated as needs change.
Nicola Harker Coaching Consultancy Ltd recognises that not all disabilities are visible. Employees are not required to disclose a specific diagnosis in order to request support.
5.4 Physical & Digital Accessibility
• Our premises will be regularly reviewed to ensure physical accessibility, and any barriers identified will be addressed promptly.
• Digital tools, platforms, and communications used by employees will be assessed against accessibility standards (WCAG 2.1 AA as a minimum).
• Job applicants can request accessible formats for recruitment materials or alternative assessment methods at any point.
6. Data Monitoring & Reporting
6.1 Why We Monitor
Nicola Harker Coaching Consultancy Ltd collects and analyses diversity data to understand the composition of our workforce, identify gaps or disparities, and measure the impact of our EDI initiatives over time. Monitoring enables evidence-based decision making and helps us to demonstrate accountability.
6.2 What We Collect
On a voluntary basis, Nicola Harker Coaching Consultancy Ltd may collect data relating to the following characteristics of employees and job applicants:
• Gender and gender identity
• Age
• Ethnicity and national origin
• Disability status
• Sexual orientation
• Religion or belief
• Socio-economic background (e.g. parental occupation, type of school attended)
Disclosure of this information is entirely voluntary. Employees are encouraged to participate so that our data is as representative as possible, but there will be no adverse consequences for those who choose not to.
6.3 Data Protection & Confidentiality
All diversity data is classified as special category personal data under the UK GDPR and will be:
• Stored securely with access restricted to authorised HR personnel only.
• Used only in anonymised or aggregated form for monitoring and reporting purposes.
• Never used to identify or make decisions about individual employees.
• Retained in accordance with Nicola Harker Coaching Consultancy Ltd's Data Retention Policy and deleted when no longer required.
The collection and use of this data is conducted in accordance with our Data Protection Policy and Privacy Notice.
6.4 Reporting & Transparency
Nicola Harker Coaching Consultancy Ltd commits to the following reporting cadence:
EDI Reporting Schedule
Annual: Publication of an internal EDI progress report covering workforce composition data, pay gap analysis (where applicable), training completion rates, and highlights from employee networks.
Bi-annual: Review of EDI metrics by the People & Culture Committee, with findings presented to senior leadership.
Ad hoc: Reports to the Board or Exec team following significant incidents, policy changes, or external developments that may impact our EDI approach.
6.5 Gender Pay Gap Reporting
Where Nicola Harker Coaching Consultancy Ltd meets the statutory threshold (250 or more employees), it will comply with gender pay gap reporting regulations and publish its report in accordance with the relevant deadline. Where below the threshold, Nicola Harker Coaching Consultancy Ltd will carry out voluntary gender pay analysis and share key findings with employees.
6.6 Using Data to Drive Action
Data gathered through monitoring will be used to:
• Identify underrepresentation at different levels of the organisation.
• Assess the effectiveness of recruitment and promotion processes.
• Set measurable EDI targets and track progress against them.
• Inform the design of training, support programmes, and policy changes.
• Report to stakeholders on our EDI commitments and progress.
7. Roles & Responsibilities
Board / Senior Leadership
Champion EDI as a strategic priority; hold the organisation accountable for progress; approve the policy and any material revisions.
HR / People & Culture
Own this policy; provide guidance and training; manage reports of discrimination or harassment; maintain diversity data; produce EDI reports.
Line Managers
Model inclusive behaviours; support team members in requesting adjustments; address and escalate concerns promptly; complete EDI training.
All Employees
Treat colleagues, clients, and third parties with dignity and respect; complete required training; raise concerns when observed.
8. Policy Review & Communication
This policy will be reviewed at least annually, or sooner in response to legislative changes, significant organisational developments, or findings from EDI monitoring. Any revisions will be communicated to all employees and made available on the Company's internal systems.
Employees who have questions about this policy or would like to discuss any aspect of EDI at Nicola Harker Coaching Consultancy Ltd are encouraged to contact HR at any time.
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•A "cookie" is a piece of information that is stored on your computer's hard drive and which records how you move your way around a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.
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•Cookies can also be categorised as follows:
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