Policies & Compliance

We are committed to operating with integrity, transparency, and accountability across every part of our business. This page provides access to our key policies, certifications, and reports, outlining how we meet regulatory requirements, protect data, support our people, and uphold the highest standards in everything we do.

ISO 9001:2015

It is the policy of Spencer Ogden to maintain a quality system designed to meet the requirements of ISO 9001:2015 in pursuit of its primary objectives, the purpose and the context of the organisation. 

It is the policy of Spencer Ogden to:

• Ensure the company maintains its awareness for continuous improvement and to continually assess potential risks to the organisation;
• Customer service (to both our clients and candidates) is an essential part of the quality process. To ensure this is fulfilled, it is the policy of Spencer Ogden to ensure all employees receive training to ensure awareness and understanding of quality and its impact on customer service;
• Ensure we are ahead of the any forecasted or pending legal requirements, codes of practice and all other requirements applicable to our activities to ensure all processes are altered to ensure compliance;
• Provide all the required resources to our trained and competent staff;
• Ensure that all employees are made aware of their individual obligations in respect of this quality policy and are fully aware of the quality objectives of Spencer Ogden;
• Ensure the Board of Directors are regularly reviewing the results of audits and the continual progressions of the Quality Management System. 

• This quality policy provides a framework for setting, monitoring, reviewing and achieving our objectives. 

You can verify the validity of our ISO certificate by entering our certificate number 200042 via this link: https://www.british-assessment.co.uk/verify-certification/

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Privacy Policy

Spencer Ogden Limited (“Spencer Ogden”) provides specialist recruitment services in the energy, infrastructure and engineering sectors. Your privacy is important to Spencer Ogden, and this privacy policy provides information about the personal information that Spencer Ogden collects, and the ways in which Spencer Ogden uses that personal information.
 
The term personal information as used throughout this policy, applies to any data relating to an identified or identifiable individual, including data that directly or indirectly identifies an individual.
Spencer Ogden is the data controller for the processing of personal information under applicable data protection law.
 
Personal information collection​

• Spencer Ogden will collect and use the following kinds of personal information:
• Information you provide to Spencer Ogden, such as information that you provide using for the purpose of registering with the website, information that you provide for the purpose of subscribing to the website services and any other information that you send to Spencer Ogden;
• Information that is automatically collected, such as information about your use of this website.
• Spencer Ogden may also collect personal information from other websites that display information about you publicly, such as: social media accounts like Facebook and Twitter, your online profile on your current employer’s network, articles about you or other public listings of your profile.
• Spencer Ogden’s use of personal information

Spencer Ogden will use the personal information it collects to perform activities associated with providing the website and website services such as:

• Enabling your access to and use of the website and the website services;
• Using Spencer Ogden’s recruitment database to match suitable candidates with roles posted by Spencer Ogden clients;
• Progressing candidates’ applications and administering their personal records;
• Recording details of unsuccessful applicants to be considered for further suitable opportunities that may arise in the near future;
• Communicating with you;
• Administering the website;
• Customizing and personalizing the website for you through the delivery of tailored content and communications;
• Improving the quality of the website;
• Resolving disputes and/or troubleshooting problems; and with your separate consent, sending you marketing communications.
• Identify and authenticate you so you may use the website;
• Necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement);
• Necessary for Spencer Ogden’s legitimate interests (for example, to manage its relationship with you and to improve the website and Spencer Ogden’s website services);
• Based on your consent (for example, to communicate about Spencer Ogden’s services and provide you with marketing information), which may subsequently be withdrawn at any time without affecting the lawfulness of processing based on consent before its withdrawal.
• You are required, as a necessity to enter into a contract, to provide Spencer Ogden with personal information for processing as described above. If you do not provide personal information, Spencer Ogden will not be able to provide you with all of the features available through the website and website services.

Sharing personal information about you

• Spencer Ogden does not disclose personal information about you through the website services, except as described in this privacy policy.
• Spencer Ogden will share with its clients personal information relating to candidates. Limited members of the Recruitment, Compliance and Customer Services, Finance, HR, IT and Legal teams in Spencer Ogden may access and otherwise process personal information in connection with their job responsibilities or contractual obligations. Your personal information may also be shared with Spencer Ogden affiliate companies and with third party providers who perform services for Spencer Ogden.
• Third party service providers will be obligated to use that personal information only in accordance with the terms of this privacy policy and applicable legal requirements. In addition to the disclosures necessary for the purposes identified above, Spencer Ogden may disclose your personal information to the extent required to do so by law, in connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend its legal rights.

Cross-border data transfers

• Personal information may be stored and processed by and transferred between Spencer Ogden affiliate companies - and third-party service providers - located in the United States of America and other countries outside of the European Economic Area, including in countries that may not provide the same level of data protection as your home country. Spencer Ogden takes appropriate steps to ensure that recipients of your personal information are bound to duties of confidentiality and Spencer Ogden implements measures such as standard data protection contractual clauses to ensure that any transferred personal information remains protected and secure. A copy of these documents can be obtained by sending an email to dataprotection@spencer-ogden.com.
• Securing your personal information Spencer Ogden has appropriate technical and organisational measures in place to prevent accidental or unlawful access to or destruction, loss, misuse or alteration of your personal information. Spencer Ogden will store all the personal information you provide on secure servers.

Automated decision making

• Spencer Ogden does not use automated decision-making technologies.

Retention of personal information

• Spencer Ogden will retain personal information only for so long as reasonably necessary for the purposes set out above, considering criteria such as applicable rules on statute of limitations and at least the duration of your use of the Spencer Ogden website and services.

Your rightts

• You may be entitled, in accordance with applicable law, to object to or request the restriction of processing of your personal information, and to request access to, rectification, erasure and portability of your own personal information. Requests should be submitted by using the contact details set out below.
• If you are aware of changes or inaccuracies in your personal information, you should inform Spencer Ogden of such changes so that its records may be updated or corrected. You may lodge a complaint with a supervisory authority if you consider that Spencer Ogden’s processing of your personal information infringes applicable law.

Other websites

• This website contains links to other websites. Spencer Ogden is not responsible for the privacy policies or practices of any third party.

Contact Spencer Ogden

• If you have any questions about this privacy policy or Spencer Ogden’s treatment of your personal information, please send an email to dataprotection@spencer-ogden.com

Updating this policy

• Spencer Ogden may update this privacy policy periodically by posting a new version on this website. You should check this page occasionally to ensure you are familiar with any changes. If the changes made to the policy are material, Spencer Ogden also may post a notice on the website prior to the effective date of the change, or, in some cases, may provide notice of the changes by email
• This policy was last updated on 24th May 2026.

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Data Protection Policy

In line with current data protection and privacy regulations, we are advising you that your details have been stored into the Spencer Ogden recruitment database, which is used to identify suitable candidates for clients.

The information you have provided as part of your application will be used to progress your application and, if your application is successful, to administer your personal record.
 
Should you be unsuccessful at this stage we will, record your details on our recruitment database in order to consider you for further suitable opportunities with our clients that may arise in the near future.
 
We take the security of your personal information very seriously and have appropriate technical and organisational measures in place.
 
We may also collect personal information which we have found from other websites that display information about you publicly. For example, social media accounts such as Facebook and Twitter, your online profile on your current employer’s network, any articles about you or any public listing of your profile.
 
Personal data which you supply to us may be transferred to third party service providers to be stored or processed on our behalf, including third parties located outside of the European Economic Area in countries where there may be a lower legal level of data protection. However, we will always endeavour to handle your information in accordance with this privacy policy, wherever it is processed.
 
Fair Collection:
Below confirms to you how we will store and process the personal information you have provided us if you have been added to our database via you registering your details on our website.
 
What information are we talking about?
Personal information is any information that can be used to identify you. The data we usually hold is your contact details but may also include your CV, identity and registration documentation (if you have registered as a candidate with us in person) and bank account details (if you have registered with us for temporary work). 
 
How do we use it?
There are no secrets when it comes to how we use your data and we only keep the information we need to carry out our recruitment services. This is all set out in our Privacy Policy so please do take a look.
 
What does this mean for you?
By holding your information, we can ensure that for our clients we keep you informed of candidates who may be suitable for your hiring needs and for our candidates, vacancies best suited to the job preferences, skills and employment experience you have on your CV. 
 
You’re in control
We will always tell you how we use your data, and we will make sure we collect and store your data safely and securely.  You can contact us at any time to request the data we hold at dataprotection@spencer-ogden.com.

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Modern Slavery & Human Trafficking Statement

Opening Statement from the Chief Operating Officer
Spencer Ogden is committed to preventing acts of modern slavery and human trafficking within its business operations and throughout its supply chain. We expect and require the same high standards from all suppliers, partners, and third parties with whom we work.
Modern slavery and human trafficking are global issues that can affect organisations across all sectors. Recognising this risk, Spencer Ogden takes a proactive approach to ensuring that all employees remain vigilant to potential indicators of modern slavery within our business and wider supply chain, regardless of the perceived level of risk.

We have implemented appropriate policies, controls, and governance measures to promote best practice and safeguard human rights. This includes robust supplier due diligence processes based on governance, ethical standards, and financial standing. All colleagues are expected to report any concerns or suspected incidents, which are reviewed and addressed promptly by management. Spencer Ogden considers these measures to be proportionate, effective, and appropriate in mitigating the risk of modern slavery and human trafficking.

Structure of the Organisation
Spencer Ogden is an award-winning global specialist recruitment consultancy operating across the critical infrastructure, renewables and sustainability, and natural resources sectors. Headquartered in London, the business has established a global presence with offices across EMEA, APAC, and the Americas, including locations such as Düsseldorf, Singapore, Houston, and Perth.
Spencer Ogden provides specialist, professional, and proactive recruitment services, partnering with skilled professionals and leading organisations worldwide to support critical projects and long-term workforce needs.

Supply Chain Overview
The recruitment sector operates within a diverse and sometimes complex supply chain, particularly for international engagements. Spencer Ogden’s supply chain includes, but is not limited to, management companies, job boards, property services, media and marketing providers, IT equipment suppliers, stationery, and print vendors. Our client base consists primarily of international energy, engineering, and infrastructure organisations.

Spencer Ogden is committed to managing its supply chain responsibly and ensuring that human rights are respected throughout all business relationships.

Supply Chain Standards, Processes, and Due Diligence
As part of our commitment to combating modern slavery and human trafficking, Spencer Ogden regularly assesses the nature and extent of any potential risks within its supply chain. We maintain processes and procedures designed to:

•    Identify and assess potential risk areas within our supply chains
•    Mitigate risks associated with modern slavery and human trafficking
•    Continually monitor and review identified risk areas
•    Protect whistleblowers through a confidential and independent reporting process

To further mitigate risk, Spencer Ogden includes commitments to the prevention of modern slavery and human trafficking within its standard terms of business with clients and candidates. Prior to engaging with any client, supplier, or third party, appropriate due diligence and compliance checks are undertaken to ensure that Spencer Ogden does not enter into relationships with organisations that have a history of involvement in modern slavery or human trafficking.

Any supplier or third party found to have engaged in such practices will have their business relationship with Spencer Ogden terminated immediately.

As standard practice, Spencer Ogden recruitment consultants communicate directly with candidates rather than through intermediaries. This direct engagement not only supports efficient and transparent recruitment processes but also provides additional assurance that Spencer Ogden is not exposed to risks associated with modern slavery. All recruitment consultants receive training upon joining the organisation to ensure they understand the importance of vigilance and compliance in this area.
The below map shows the locations of our suppliers against the most recent Global Slavery Index, of which over 98% are based in countries considered between medium to very low risk.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Spencer Ogden’s slavery and human trafficking statement for the current financial year.

Tom Reid
Chief Operating Officer
January 2026

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Complaints Procedure
 
If you have a complaint about Spencer Ogden staff or contractors, please write to:
Helen Lawrence Group Head of Compliance and Contractor Services (Email: helen.lawrence@spencer-ogden.com)
Spencer Ogden Limited 24 King William Street Third Floor London EC4R 9AT

 
For matters concerning the EMEA region: We will send you a letter or email, acknowledging your complaint and confirming its receipt. You should expect to receive this confirmation within 7 working days of us receiving your complaint. We will then record your complaint in our central register and start to investigate on your behalf. This is likely to involve the following steps: a. Examining your records to ascertain the sequence of relevant events. b. Asking the member of staff with whom you dealt to provide a written response. A full response to your complaint will be drafted by Helen Lawrence or the consultant who is dealing with your file. If appropriate, we may wish to discuss the events surrounding your complaint directly with you and, if appropriate, offer an apology.  We aim to acknowledge, investigate and resolve all complaints within 21 working days of receipt.  Should you feel your complaint has not been dealt with in a satisfactory manner, you are entitled to request that your complaint be raised to our Board of Directors for investigation by them. Following this, a Director will be in touch with you to discuss the issue.
 
If you are a contract worker engaged under assignment as a seafarer, should you feel your complaint has not been adequately resolved, you have the right to escalate any issues you may have to mlc@mcga.gov.uk

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LCA Notices - Click to View

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Zero Tolerance Policy

Introduction and Scope

This policy outlines the types of behaviours that the business does not tolerate both towards and from its staff and should act as a guide for our external stakeholders. It applies to anyone that interacts with a member of Spencer Ogden’s workforce (including clients and contractors) through any form of communication. Spencer Ogden prides itself on the steps it takes and commitment that it makes to providing its staff with a safe workplace where mutual respect is given.  

Unacceptable Behaviours

Below are several of the behaviours that the business does not deem as acceptable. Please note that this is not an exhaustive list but should provide some guidance around our expectations. 

Harassment and Sexual Harassment

Spencer Ogden considers harassment (in any form, including sexual harassment) to be unacceptable and potentially unlawful. Harassment is defined as unwanted conduct that has the purpose or effect of violating the dignity of a person or of creating an intimidating, hostile, degrading, humiliating or offensive environment. This conduct will be unwanted by the recipient and can include physical, verbal, or nonverbal conduct. It can also include circulating information or images via e-mail or the internet. Sexual harassment can be defined as unwanted verbal, non-verbal or physical conduct of a sexual nature which has the purpose or effect of violating the recipient's dignity, or of creating an intimidating, hostile, degrading, humiliating or offensive environment for the recipient. 

Aggressive, Threatening or Abusive Behaviour

Spencer Ogden deems it unacceptable for any form of aggression, threat or abuse to be directed towards our staff. Aggressive, threatening or abusive behaviour includes language (verbal or written) that may cause staff to feel afraid or vulnerable. Examples of such behaviour may include threats, personal verbal abuse, derogatory remarks or rudeness.  Abusive behaviour may also include inflammatory statements, remarks of a racial or discriminatory nature and unsubstantiated allegations. 

Unreasonable Demands

Spencer Ogden will consider a demand to be unreasonable when it understands it to have an excessive impact on the work of our staff or when dealing with the matter takes up an excessive amount of time and resource, preventing our staff from carrying out their duties. 

Implementing the Zero Tolerance Policy

The business will manage behaviour we consider falling under the above categories in line with our internal policy, details of which are outlined below. 

• Our staff have the authority to advise individuals their behaviour is unacceptable and to ask for it to stop.
• Should the behaviour continue our staff have the authority to immediately cease communicating with the perpetrator and/or their employer.
• Our staff will report the incident(s) to our internal Human Resources Team to take action that they deem appropriate to the circumstances.  

The business will confirm the action taken to the appropriate personnel following our internal investigation. Please note that should the business consider it appropriate to do so, in extremely serious instances, we may make the decision to contact the authorities.  

External Stakeholder Protection

Although, this policy is created with the intention to protect our workforce, we recognise that the individuals we as a business interact with deserve to be treated with equal amounts of dignity and respect. For this reason, we have taken reasonable steps to educate our staff on acceptable behaviours, to protect those with whom they interact. This policy is overseen by Spencer Ogden’s Human Resources and Compliance Departments, any comments or concerns may be directed to askhr@spencer-ogden.com  or emeacompliance@spencer-ogden.com. 

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