1. Policy statement
Luma Education Recruitment Ltd ("Luma") competes fairly and on merit. We comply with the Competition Act 1998 and the Enterprise Act 2002, which prohibit agreements between businesses that prevent, restrict or distort competition. Breaches can lead to fines of up to 10% of worldwide turnover, disqualification of directors and, for cartel offences, criminal prosecution.
Education recruitment is a busy market with many agencies working with the same schools and on the same frameworks, so this policy sets out clear rules.
2. What we will never do
We will never agree or coordinate with a competitor, directly or indirectly, to:
- fix or align pay rates, charge rates, mark-ups, margins, transfer fees or discounts;
- share out schools, trusts, areas, frameworks or candidates between us;
- rig bids, for example by agreeing who will win a tender, submitting a deliberately high "cover" bid, or not bidding;
- agree not to recruit each other's staff or workers ("no-poach" agreements);
- limit the services we offer or boycott a client, supplier or candidate.
3. Sharing information
- We do not share commercially sensitive information with competitors. That includes our current or future prices, rates, margins, costs, tender strategies, client lists and business plans.
- If a competitor shares this kind of information with us, we will not use it. We will make clear that we do not want to receive it and record what happened.
- When we work alongside other agencies, for example on a framework, through a master vendor or managed service, or when a school asks several agencies to fill the same vacancy, we share only the information needed to deliver the service and nothing about pricing or strategy.
4. Trade associations and industry events
We are members of APSCo and take part in industry events and framework supplier meetings. These are legitimate, but conversations must never turn to prices, margins, tenders or which clients each agency works with. If they do, we will object, leave the discussion and make sure the objection is recorded.
5. Tenders and frameworks
Every tender and framework response is prepared independently by Luma. Pricing is set by the directors alone. We declare any relationship with another bidder where a tender requires it, and we follow the procurement rules of the contracting authority, including the Procurement Act 2023.
6. Dealing fairly with clients and candidates
Our terms of business, including transfer fees, are set out clearly to clients in advance and comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003. We do not stop workers from taking work directly with a school or through another agency, other than through the lawful terms set out in our terms of business.
7. Reporting concerns
If you think this policy may have been breached, or you are unsure whether something is allowed, speak to Daniel Benson, Director (daniel.benson@lumaedrec.com, 0204 576 4344) before acting. You can also use our whistleblowing procedure.
8. Review
This policy is reviewed every year, or sooner if the law changes.