1. Purpose
This policy sets out Murzo Group's approach to employment and workplace management in the Turks and Caicos Islands.
It is designed to support fair treatment, lawful employment, clear contracts, proper payment, reasonable workplace controls, fair disciplinary and grievance handling, and legally defensible termination decisions.
2. Scope
This policy applies to TCI employees and, where suitable, workers, agency workers, interns, secondees, temporary staff, work-permit holders, contractors, consultants, local managers, site contacts, and any person working under the Group's direction in TCI.
For non-employees, the Group may use contract controls, site rules, access restrictions, supplier escalation, or termination of engagement instead of employee disciplinary sanctions.
3. TCI Legal Framework
Employment in TCI is governed by local law, including the Employment Ordinance, Employment Order, Immigration Ordinance, work permit rules, Labour Tribunal procedures, national insurance, national health, public holiday, health and safety, equality, and other workplace requirements that may apply to the role or sector.
UK employment rules, ACAS practice, or UK contract templates may be useful as internal standards, but they must not be treated as replacing TCI requirements. Where UK obligations continue to apply because of the Group's UK base, those obligations should be applied alongside TCI law where lawful.
4. Employment Status and Worker Classification
Before work starts, the Group must identify whether the person is an employee, worker, contractor, consultant, secondee, agency worker, intern, volunteer, director, freelancer, or supplier personnel.
The label used in a contract must match the practical working arrangement. A person must not be described as self-employed, freelance, visiting, temporary, unpaid, or supplied by another party to avoid wages, leave, work permit, tax, national insurance, national health, dismissal, or workplace obligations.
5. Right to Work, Work Permits and Local Recruitment
No person may perform work in TCI unless their right to work, immigration status, work permit, temporary work permit, labour clearance, local recruitment step, and any work permit condition have been checked before duties begin.
Where a role requires a work permit, the Group must consider current TCI advertising, local labour market, TCI Islander preference, health, police record, housing, contribution, renewal, and immigration requirements.
A work-permit holder must work only within the approved role, employer, location, and conditions unless the competent TCI authority approves a change.
6. Contracts and Written Terms
Each TCI employee should receive clear written terms before or at the start of employment, or as soon as reasonably practicable where local law allows. Contract terms should be understandable, lawful, and consistent with the approved role and business licence position.
Contracts should normally address the employer identity, employee identity, start date, job title, place of work, reporting line, duties, probation, hours, wages, pay frequency, overtime, leave, public holidays, sickness, benefits, housing or allowances where relevant, confidentiality, data, systems access, disciplinary and grievance routes, notice, termination, final pay, return of property, and governing law.
Any contract term that is less favourable than a mandatory TCI employment right must be treated as subject to applicable law.
7. Probation, Role Changes and Secondments
Probationary periods must be reasonable, transparent, and consistent with the contract. Probation does not remove mandatory wage, safety, discrimination, immigration, or fair treatment obligations.
Role changes, promotions, demotions, transfers, secondments, location changes, hours changes, pay changes, or major duty changes should be confirmed in writing where material. Where a change affects a work permit, licence, tax, payroll, housing, or immigration condition, it must not take effect until the required authority position is clear.
8. Wages and Pay
Employees must be paid at least the minimum rate required by current TCI law, order, sector rule, contract, collective agreement, or binding authority decision. Pay must be accurate, timely, and transparent.
Wage arrangements should address basic pay, hourly or salary basis, overtime, public holiday work, service charge or gratuity handling where applicable, commissions, bonuses, allowances, expenses, housing benefits, deductions, statutory contributions, and final pay.
Managers must not make informal pay promises, cash arrangements, off-payroll payments, unauthorised deductions, unlawful fines, disguised commissions, or undocumented changes to wage terms.
9. Hours, Rest and Overtime
Working hours must comply with the contract and current TCI working time requirements. Rosters should be planned so that ordinary hours, overtime, rest periods, meal breaks, night work, public holiday work, and sector-specific rules are clear.
Overtime should be approved in advance where possible, paid or compensated in accordance with applicable law and contract terms, and not used to avoid hiring, safety, fatigue, or immigration requirements.
Managers must not pressure employees to under-report hours, work unpaid time, work during leave without approval, or breach work permit or safety limits.
10. Holidays, Leave and Absence
Employees are entitled to holidays, public holidays, vacation, sick leave, maternity or family-related leave, and other statutory or contractual leave in accordance with current TCI law and their contract.
Leave arrangements should be planned fairly and with regard to business needs, employee wellbeing, staffing levels, immigration conditions, and safety. Employees should follow absence notification and medical evidence requirements where lawful and reasonable.
The Group must not force leave, cancel leave, withhold accrued leave, or treat absence as misconduct unless the action is lawful, reasonable, and supported by the facts.
11. Workplace Standards and Conduct
Employees are expected to act honestly, safely, professionally, and respectfully. This includes following lawful instructions, protecting confidential information, using systems properly, treating colleagues and customers with dignity, reporting hazards, and avoiding conduct that may damage people, property, products, data, customers, suppliers, or the Group's reputation.
Local managers must lead by example and must not tolerate bullying, harassment, discrimination, intimidation, unsafe work, wage abuse, retaliation, unauthorised surveillance, sexual misconduct, violence, theft, fraud, bribery, drugs, alcohol misuse, or misuse of authority.
12. Health, Safety, Welfare and Accommodation
Workplaces must be managed with suitable attention to safety, hygiene, welfare, training, supervision, emergency arrangements, first aid, equipment, PPE, fatigue, heat, transport, lone working, food handling, chemicals, animals, insects, security, and customer-facing risk where relevant.
Where the Group provides or arranges accommodation, transport, meals, uniforms, tools, phones, devices, or other work-related support, the arrangement must be lawful, safe, documented where material, and not used to undermine wages, freedom, dignity, or immigration status.
13. Confidentiality, Systems Access and Evidence
Employees must protect confidential information, customer information, staff information, supplier information, product data, legal material, financial information, trade secrets, premises information, CCTV material, and systems credentials.
The Group may restrict access to premises, documents, systems, devices, accounts, email, cloud services, customer records, financial systems, or physical assets where reasonably necessary for security, investigation, handover, suspension, role change, or termination.
14. Grievances
Employees may raise concerns about work, pay, hours, leave, treatment, discrimination, bullying, harassment, safety, management decisions, workload, contract terms, disciplinary handling, or other workplace issues.
Informal resolution may be suitable for some matters, but formal grievances should normally be raised in writing so the issue, facts, dates, people involved, impact, and requested outcome can be understood.
Grievances should be handled fairly, confidentially where possible, without retaliation, and with suitable investigation, meeting, outcome, and appeal steps where appropriate.
15. Disciplinary Principles
Disciplinary matters should be handled fairly, proportionately, and without unlawful discrimination. The process should usually include a reasonable investigation, notice of the concern, an opportunity for the employee to respond, consideration of evidence, a reasoned outcome, and an appeal where appropriate.
Possible outcomes may include no action, informal guidance, training, management instruction, written warning, final written warning, role or access change where lawful, disciplinary suspension where permitted, dismissal with notice, summary dismissal for gross misconduct where justified, or another lawful and proportionate outcome.
Examples of misconduct may include breach of contract, unauthorised absence, poor timekeeping, refusal to follow lawful instructions, poor conduct, safety breach, confidentiality breach, unauthorised systems access, misuse of company property, harassment, discrimination, violence, theft, fraud, bribery, substance misuse at work, falsification of records, or serious customer, product, security, immigration, regulatory, or reputational risk.
16. Investigations
Investigations should be no broader than reasonably needed to understand the issue. They may include interviews, document review, system logs, CCTV where lawful, access records, customer or witness statements, financial information, product or stock checks, device checks where authorised, and legal or specialist advice.
Investigations must not be used to intimidate, predetermine guilt, search private material unlawfully, retaliate against an employee, or interfere with a genuine grievance or whistleblowing concern.
17. Investigatory Suspension
Where reasonably necessary to protect employees, customers, business property, confidential information, evidence or the integrity of an investigation, the Company may suspend an employee from duties or restrict their workplace and systems access. Investigatory suspension will normally be on full basic pay with contractual benefits and shall not constitute a finding of misconduct or disciplinary penalty. The suspension shall be kept under regular review and maintained only for so long as reasonably necessary.
18. Disciplinary Suspension
Following completion of a fair disciplinary procedure, the Company may impose a disciplinary suspension with or without pay where expressly permitted by the employee's contract and applicable law. Any suspension without pay shall be reasonable and proportionate, shall apply only for the specified prospective period and shall be confirmed in writing. The Company shall not withhold wages already earned or impose an unauthorised fine or monetary penalty.
19. Restitution and Deductions
Where the Company has sustained an evidenced financial loss caused by an employee's established conduct, no deduction or restitution shall be imposed unless it is lawful and expressly agreed in writing by the employee or otherwise authorised by law. Restitution shall not be used as a substitute for a fair disciplinary procedure.
Deductions from wages, final pay, holiday pay, service charge, gratuities, expenses, accommodation charges, equipment costs, training costs, damage claims, stock losses, loans, advances, or alleged losses must be lawful, transparent, proportionate, and supported by contract or written authorisation where required.
20. Termination and Final Pay
Termination may occur by resignation, expiry of a fixed-term contract, mutual agreement, dismissal with notice, summary dismissal, redundancy, incapability, work permit issue, frustration, retirement where lawful, or another lawful route.
Before dismissal, the Group should consider the reason, evidence, contract, notice, statutory rights, warnings, alternative work, mitigation, immigration consequences, housing arrangements, accrued leave, final pay, benefits, expenses, return of property, confidentiality, handover, and whether local legal advice is required.
Final pay must be calculated lawfully and should address earned wages, approved overtime, accrued contractual or statutory entitlements, authorised deductions, expenses, service charge or gratuity position where applicable, and any payment in lieu of notice or severance where required.
21. Redundancy, Layoff and Reduced Hours
Redundancy, layoff, short-time working, reduced hours, unpaid leave, contract variation, or restructuring must not be imposed informally. The Group should consider consultation, contractual authority, current TCI law, business reasons, selection fairness, immigration consequences, notice, pay, and alternatives before action is taken.
Where agreement is needed and is not reached, existing contract terms may continue unless local law permits another lawful route.
22. Work Permit Holders on Termination
Where employment ends for a work-permit holder, the Group must consider any ongoing TCI immigration, housing, repatriation, notification, transfer, and work permit cancellation or change requirements.
The Group must not release a work-permit holder to another employer, allow work outside approved conditions, or ignore immigration status after termination unless the competent TCI authority has approved the position.
23. Appeals and Labour Tribunal Matters
Where appropriate, employees should be given an appeal route for disciplinary, dismissal, or grievance outcomes. Appeals should be handled by a suitable person who was not materially involved in the original decision where practicable.
Employment disputes, complaints, or labour matters may be referred to the TCI Labour Tribunal or other competent authority where the law allows. The Group will respond to authority communications only through authorised representatives.
24. Managers, Third Parties and Authority Limits
Managers, agents, recruiters, payroll providers, accommodation providers, work permit advisers, security providers, and local representatives must not issue employment promises, settlement offers, disciplinary outcomes, termination notices, pay changes, immigration statements, or authority responses unless authorised.
Unauthorised promises or acts by third parties do not bind the Group unless approved in writing by an authorised person or required by law.
25. Review and Responsibility
Directors, managers, HR contacts, payroll contacts, local representatives, and contract owners are responsible for applying this policy to TCI workplace activity under their control.
This policy should be reviewed when TCI employment law, immigration rules, work permit rules, minimum wage orders, public holiday rules, Labour Tribunal practice, national insurance or health obligations, sector rules, or local operations change.
