Operated by: Nudge Education Ltd · Version: Dec 2025 · Owner: Director of Operations

BUSINESS CONTINUITY MANAGEMENT PLAN

Last review: December 2025 Next review due: March 2026

Detailing arrangements for:

Incident Management Business Continuity Recovery and Resumption of Normal Business Emergency & Evacuation Plans COVID-19 Protocol

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About this Plan 1.0Document Control Date Revision/Amendment Details & Reason Author 28/03/2018 V1.0 of plan Brian Mair 31/03/2019 V2.0 of Plan Brian Mair 24/03/2020 V3.0 of Plan Brian Mair 27/3/2021 V4.0 of Plan Brian Mair 22/3/2022 V5.0 of Plan Brian Mair 22/3/2023 V6.0 of Plan Brian Mair 29/3/2024 V7.0 of Plan Brian Mair 22/10/2024 v.8.0 of Plan Marcos Rojo 3/4/2025 V.9.0 of Plan Brian Mair 5/12/2025 V9.1 of Plan Brian Mair

1.1 Plan Purpose

To provide a flexible response so that the Directorate of Nudge Education can:

  • Respond to a disruptive incident (incident management)
  • Maintain delivery of critical activities/services during an incident (business continuity)
  • Return to ‘business as usual’ (resumption and recovery)

1.2 Plan Remit

The following activities/services/functions are covered by this Plan:

  • Operational Delivery of tuition and engagement
  • ICT systems and operations
  • Financial control
  • Safeguarding
  • Health and Safety
  • Strategic control of overall organisation (Director level)

The following sites are covered by this Plan:

  • Nudge Education Offices:

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a) Sirius House, Amethyst Road, Newcastle-upon-Tyne, NE4 7YA b) Office P4 The Knoll Business Centre, Old Shoreham Rd, Hove BN3 7GS

  • Any other site hired by Nudge Education for the purpose of tuition, engagement or administrative work

1.3 Plan Owner

Brian Mair, Director of Operations Lead is this Plan’s Owner and responsible for ensuring that it is maintained, exercised and updated in accordance with internal requirements for business continuity1.

1.4Plan Distribution This Plan is distributed as follows:

NAME ROLE Diego Melo CEO Brian Mair Director of Operations, H & S Lead, National Safeguarding Lead Charlotte Noutch Director of Service Delivery Claire Falcus Legal Lead & Operations Manager

1.5 Plan Storage

Electronic copies of this Plan are stored:

https://docs.google.com/document/d/1WlZNwsMsqZVdAj1pJjDhsKLh1 hXp6DBaagxWDU5yT0I/edit?usp=sharing

1.6 Plan Review Date

This Plan will be updated annually unless emergency protocols change and formally reviewed in March 2026

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2.0 Plan Activation

2.1 Circumstances

This Plan will be activated in response to an incident causing significant disruption to normal service delivery/business, particularly the delivery of key/critical activities. Examples of circumstances triggering activation of this Plan include:

  • Loss of key staff or skills e.g. above normal levels of absenteeism due to illness
  • Loss of critical systems e.g. ICT failure
  • Denial of access, or damage to, facilities e.g. loss of a building through fire
  • Loss of a key resource e.g. a major supplier vital to the delivery of a key service

2.2 Responsibility for Activation

Brian Mair, Director of Operations will normally activate and stand down this Plan:

Name Role Office Out of Mobile Office Brian Mair Director of 0191 0754589850 07958440937 Ops 4862131 7 Diego CEO 0191 07796452916 07796452916 Melo 4862131

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2.3 Process for Activation

The process for activation is set out in the diagram below:

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3.0 Incident Management

For the purpose of the document, the incident management protocols shall be developed in conjunction with the host venue’s own procedures when Nudge Education is hiring a temporary venue for the purpose of tuition and engagement for students.

3.1 Purpose of the Incident Management Phase

  • Protect the safety of staff, students and the wider community
  • Protect vital assets e.g. equipment, data, reputation etc
  • Ensure necessary communication takes place

3.2 Actions to protect the safety and welfare of

staff, students and the public.

The following actions will be taken to protect the immediate safety of staff, visitors and the public:

ACTION FUTHER INFO/DETAILS 1 Evacuate the building if Use normal evacuation procedures for necessary the building as per H & S induction. 2 Ensure all staff & The Assembly point for the Nudge students report to the Education Office is: Assembly Point. Front Car Park (Sirius House, Amethyst Road) Rear Car Park (Hove Office)

The designated fire warden () is responsible for completing this action.

In occasions where Nudge Education are hiring an alternative venue, the relevant senior manager will be responsible for evacuating the student and additional staff members in conjunction with the venue’s own action plan.

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3 Call emergency services TEL: 999 (as appropriate) Fire Warden/ relevant senior manager is responsible for completing this action depending on venue 4 Check that all staff, Charlotte Noutch/Brian Mair/Claire students and any Falcus will be responsible for this at visitors have been Nudge Education’s office, evacuated from the building and are The relevant senior manager is present. Consider safety responsible for completing this action of all staff, students and in externally hired venues. visitors as a priority. 5 Ensure log of incident is The log template can be found at started and maintained https://form.asana.com/?k=A7ISOEdm throughout the incident 7_HicmHDmDb0vQ&d=1361310835824 phase 84 6 Record names and Brian Mair will be responsible for this details of any staff, at Nudge Education’s office, contractors or visitors who may have been The relevant senior manager is injured or distressed in responsible for completing this action the incident. in externally hired venues, 7 Forward details of any Brian Mair will be responsible for this fatalities or injuries in at Nudge Education’s office, the incident to H & S Designated Person The relevant senior manager is (depending on scale of responsible for completing this action incident) and agree in externally hired venues, action that will be taken. 8 Assess impact of the Brian Mair are responsible for incident to agree completing this action response / next steps 9 Log details of all items Brian Mair will be responsible for this lost by staff, visitors etc at Nudge Education’s office, as a result of the incident The relevant senior manager is responsible for completing this action in externally hired venues, 10 Consider whether the Depending on the incident the involvement of other following may be approached to assist teams, services or with incident management: organisations are ● Health and Safety (Brian Mair and required to support the

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management of the Kym Allan, External H & S incident Consultants Tel: 01228 210152 Website: www.kymallanhsc.co.uk

  • Insurance (Markel: Policy Number S34798) Our Broker is Gallagher, Clipper House, Chester Road, Sale, M32 8AF
  • Mobile: 07752 470410
  • E-mail: adam_wheelhouse@ajg.com

3.3 Communication Actions

In the event of an incident and this plan being activated, the following people should be contacted. Nature of contact will depend on the incident type and time it has occurred.

Diego Melo is responsible for completing the communication actions

ALWAYS CONTACTED

 Name Role Contact Likely message Details

1. Brian Director of 07958440937 ● Incident is taking

Mair Operations place

  • Action being taken
  • Impact on the service
  • Request to escalate or support

2. Diego CEO 07796452916 ● Incident is taking

Melo place

  • Action being taken

  • Impact on the service

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CONTACTED DEPENDING ON INCIDENT [add or amend as required] Name Role Contact Likely message Details

3. Charlotte Acting Director 07939842332 ● Incident is taking place

Noutch of Service ● Action being taken Delivery ● Impact on the service

  • Indication of any press interest
  • Areas they can support service e.g. updating web site/intranet, social media etc

4. Various Staff As per staff ● Incident is taking place

records on ● Action being taken Parim or Talos ● Impact on the service

  • Where they need to report to/work from

5. Various Key Suppliers & As per ● Incident is taking place

Contractors contractor ● Action being taken records. ● Impact on the service

  • Where they need to report to/work from

6. Students & N/A As per ● Incident is taking place

families student’s ● Action being taken emergency ● Impact on the service contact ● Expected duration of details. the disruption Message also to be posted through Facebook/ Twitter account as necessary

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3. 4 Actions to Support Business Continuity

 ACTION FURTHER INFO/DETAILS

1. Recover vital ● The essential resources & information

assets/equipment to that need to be recovered where enable delivery of critical possible are stored on secure Google activities2 Drive. This data is backed up on external hard drive stored in Nudge Education Office.

  • Additional ICT or telecommunications devices can be purchased from emergency fund prior to any subsequent insurance claim.

2. Assess the key priorities for ● Consider sending staff home, to

the remainder of the additional site or potential for home working day and take working. relevant action

  • Inform all commissioners of situations where students are involved.
  • Find alternative venues for delivery should this be an option.

3. Inform staff what is ● Relevant senior manager(s) to find

required of them alternative venues for next days

  • Communication Officer to draft press release if necessary and internal communication bulletin to issue to staff and contractors.

4. Publicise the interim ● Ensure all stakeholders are kept

arrangements for delivery informed of contingency of critical activities arrangements as appropriate via telephone, internet and social media where appropriate.

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  • Hold emergency meetings with teams where geography allows for it without causing further risk.

3.5 Actions to Support Recovery and Resumption

ACTION FURTHER INFO/DETAILS

1. Take any salvage/asset Remove any equipment, furniture,

recovery actions that are records etc that are at risk of appropriate damage.

2. Continue to log all Use a financial expenditure log to

expenditure incurred as a record costs incurred as a result of result of the incident responding to the incident

3. Seek specific advice/

inform your Insurance Company

3.6 Communicating with Staff

It is highly likely that staff will need to be informed about a business disruption and actions being taken to ensure the continuity of the Service. Management may also have to contact staff out of hours to advise them of any alterations to working conditions e.g. relocation of the Service to an alternative site. All staff members’ contact details should be recorded for this purpose. Contact details change, it is therefore important to ensure a process is in place to ensure details recorded in this plan are kept up-to-date.

An up to date contact log for staff is stored on our secure Google Drive and also hosted on our scheduling software www.parim.co

There will also be a live staff log-in record using our attendance system: https://signinapp.com/

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And we will be able to monitor activity and staff wellbeing via the CCTV camera system :

https://ieu.hik-connect.com/views/login/index.html#/main/overview

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4.0 Business Continuity

4.1 Purpose of the Business Continuity Phase

The purpose of the business continuity phase of response is to ensure that critical activities are resumed as quickly as possible and/or continue to be delivered during the disruption.

4.2 Critical Activities

The outcome of the Business Analysis process has been to identify the following activities as critical:

Brief Description of Critical Activities

1. Inform commissioners about disruption to services

2. Inform staff and contractors about changes to working practices

3. Training and re-distribution of duties where essential

4. Relevant Insurance Claims to recover lost property and

resources

5. Communication & Public Relations management

6. Reporting of Injuries/ Fatalities to RIDDOR and associated

agencies.

7. Re-instatement of ICT systems and re-distribution of Essential

Data (via secondary storage drive.)

4.3 Non-Critical Activities

A number of activities are non-critical and consideration will be given to:

  • Not recovering these activities until critical activities have been resumed
  • Suspending these activities and diverting their resources to support the critical ones

The non-critical activities for this team/service/organisation are:

Brief Description of Non-Critical Activities

1. Marketing activities to resume post crisis/event

2. Cancellation of non-essential meetings and training exercises

3. Administrative functions not concerning continuity plans

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4.4 Business Continuity Actions:

The Business Continuity Team (See Section 2.2) for the incident is responsible for ensuring the following actions are completed:

ACTION FURTHER INFO/DETAILS

1. Identify any other staff Depending on the incident, the

required to be involved in Business Continuity Unit may need the BC response additional/specific input in order to drive the recovery of critical activities

2. Evaluate the impact of Use an incident impact assessment

the incident form to understand the impact of the incident on ‘business as usual’ working activities.

3. Plan how critical activities Consider:

will be maintained. ▪ Immediate priorities ▪ Communication strategies ▪ Deployment of resources ▪ Finance ▪ Monitoring the situation ▪ Reporting

4. Log all decisions and Use a decision and action log to do

actions, including what this you decide not to do and include rationale

5. Log all financial Use a financial expenditure log to do

expenditure incurred this

6. Allocate specific roles as Roles allocated will depend on the

necessary incident and availability of staff

7. Secure resources to Consider requirements such as the

enable critical activities to staffing, premises, equipment. continue/be recovered

8. Deliver appropriate Ensure methods of communication

communication actions and key messages are developed as as required appropriate to the needs of your key stakeholders e.g. customers, suppliers, staff, Executive Boards, Shareholders etc.

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5.0 Recovery and Resumption

5.1 Purpose of the Recovery and Resumption

Phase

The purpose of the recovery and resumption phase is to resume normal working practises for the organisation. Where the impact of the incident is prolonged, normal operations may need to be delivered under new circumstances e.g. from a different building.

5.2 Recovery and Resumption Actions

ACTION FURTHER INFO/DETAILS

1. Agree and plan the actions Agreed actions will be detailed in an

required to enable recovery and action plan and set against resumption of normal working timescales with responsibility for practises completion clearly indicated.

2. Continue to log all expenditure Use a financial expenditure log to do

incurred as a result of the this incident

3. Respond to any long terms Depending on the nature of the

support needs of staff incident, the Business Continuity Team may need to consider the use of Counselling Services e.g. internal Occupational Health involvement or appropriate External Agencies

4. Carry out a ‘debrief’ of the Use an Incident Report Form to do

incident and complete an this. This should be reviewed by all Incident Report to document members of the Business Continuity opportunities for improvement Team to ensure key actions resulting and any lessons identified from the incident are implemented within designated timescales

5. Review this Continuity Plan in Implement recommendations for

light of lessons learned from improvement and update this Plan. incident and the response to it Ensure a revised version of the Plan is read by all members of the Business Continuity Team

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6. Publicise that there is now Board of Directors to draft statement

‘business as usual’ and distribute via social media, website and internal comms. Also to decide agreed verbal ‘script’ for telephone enquiries. All media enquiries to be directed to Directorate via holding statement.

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INITIAL RISK ASSESSMENT: Example template

Probability (Likelihood) Low Medium High

Imp High 3 6 9 act (Co nse Medium 2 4 6 que nce s) Low 1 2 3

Probability of risk occurring (P)

Low (<30%) Medium (31-70%) High (>70%)

Impact of risk occurring (I)

Low = Negligible impact on service Medium = Significant impact on service High = Service stopped

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Risk analysis

Impact / Unchecked Significance Existing Control Ownership / Risk I P Probability Potential Measures Responsibility Score Consequence

  1. Loss of Information 1 3 3 ● Not able to fulfil ● Loss of income ● Main ● Brian Mair
  • IT– essential care requirements ● Loss of services information information ● Financial – not ● Risk to backed up once

  • Financial able to invoice registration regularly by

  • Contractual ● Therapeutic Google. All data

  • Staff information needs not met backed up via including training ● Not able to meet external hard records regulatory drive once a

  • Policy and requirements week. Operational ● Admin and Documents accounting information

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backed up separately

  • Standalone information to be backed up once a week
  • Standalone Parents contact details
  1. Extreme weather 2 3 6 ● Damage to ● Staff/Students at ● Key contact ● Directorate to (e.g. floods/high property risk details of staff manage winds) ● Staff not able to ● Severe - and students strategic get to homes injury/death kept by senior operations
  • Injury to ● Potential health management – ● Acting Director students/staff and safety staff on duty of Service significance might be Delivery to required to stay follow protocols on duty for each
  • Monitor weather commissioned student
  1. Key staff shortage 3 1 6 ● Therapeutic ● Safeguarding ● Internal cover ● Education needs not met ● Reputation ● Low turnover of Intervention
  • Unable to meet ● Registration staff Co-ordinators requirements ● Skills and directorate requirements to be updated regularly
  1. Loss of 1 1 1 ● Not able to back ● Reputational ● Mobiles work in ● Operations & telecommunication up information certain places. Communication s off site Staff made s Co-ordinator
  • External aware. contacts not ● office in maintained admissions worker to work from venue

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  • Contact details

  • Remote access: Staff to use personal phone

  1. Loss of utility 1 2 2 ● Keeping ● Impact on care ● Source ● Practitioners in (elec/gas/water/sew students warm ● Safeguarding alternative liaison with age) ● Keeping food issue venue for Education
  • Hydration student Intervention
  • Cleanliness and Co-ordinators infection control
  • Students disrupted impacting on behaviour
  1. Student H&S 1 3 3 ● Injury – ● Safeguarding ● Full risk ● Practitioner in incident / clients/staff/visit issues assessments liaison with H & communicable ors ● Reputational ● Behaviour & S Single Point of diseases ● Sickness ● Claims Restraint policy, Contact (SPoC)
  • Challenging ● Accident to ● Communication lone working Brian Mair or behaviour leading client with family and policy Safeguarding to injury ● Hazards e.g. significant ● Full training DDSL, ,

  • Accident chemicals others plan Charlotte

  • Road Traffic ● Reporting ● Induction Noutch Accident requirements to process for staff, Ofsted and contractors and RIDDOR students

  • H & S procedures in place in venue food hygiene, legionella checks etc

  • COSHH

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  • Communication details maintained

  1. Negative publicity / 1 2 2 ● Loss of ● Impact on staff ● Business ● and Brian Mair coverage / damage confidence and morale continuity plan to image / potential ● Impact on ● Single point of reputation business business contact
  • Risk from poor ● Anxiety caused identified inspection to students and ● Good significant therapeutic others planning and behaviour management
  • Good health and safety practice
  1. Loss of building / 1 3 3 ● Therapeutic ● Safeguarding ● Essential care ● Practitioner in access to site needs ● Need alternative information liaison with H &
  • HQ functions accommodation ● Business Impact S Single Point of Analysis Contact (SPoC) completed Brian Mair/
  • Insurance in place
  • Sourcing of alternative venue is relatively simple.
  1. Fire 1 3 3 ● Therapeutic ● Students at risk ● Fire risk ● Practitioner in needs not met ● Severe - assessments liaison with H &
  • Serious injury or injury/death observed upon S Single Point of death ● Need to relocate point of hire Contact (SPoC)

  • Damage to and replace ● Maintenance Brian Mair/ property buildings and testing of

  • Significant (rebuild or equipment insurance cost alternative sites) ● Fire wardens

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  • Fire awareness training

  • Business Impact Analysis completed

  • Insurance in place

  1. Environmental 1 3 3 ● Chemical ● Clients at risk ● Place of safety ● Practitioner in disruption disaster ● Severe - ● Staff training liaison with H &
  • Slippage injury/death S Single Point of
  • Need to relocate Contact (SPoC) Brian Mair
  1. Safeguarding 3 1 3 ● Student ● High loss of ● Policy – whistle ● Practitioner in concern ● Reputational business blowing liaison with
  • Ofsted ● Safer Safeguarding consequences recruitment SPoC, Brian
  • Loss of business ● Training Mair,
  • Legal ● Supervision and
  • Financial observation of practice
  • Care plans reviewed
  1. Pandemic 3 3 9 ● Student ● Ongoing ● Health and ● Brian Mair (Influenza, engagement viability of Safety Policy Coronaviruses etc.) ● Spread of virus Nudge ● Individual Risk to wider Education and Assessments PLEASE SEE COVID-19 population supply chain ● Official specific protocol ● Serious illness or would be at risk Government below death to Guidance students, staff, ● Home or remote associates and working policies key stakeholders ● Option to move interventions to

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  • Complete online disruption to engagement business and dropping off activities of resource
  • Potential legal packs claims

COVID-19 PROTOCOLS

The ongoing COVID-19 (Coronavirus) pandemic has required Nudge Education to provide more flexible delivery of education interventions via socially-distanced face to face sessions, creation of resource packs to deliver to student’s home to engage in remote learning and online delivery via video-conferencing software.

We have taken the following sources as advice for our protocol:

https://www.nhs.uk/conditions/coronavirus-covid-19/ https://www.gov.uk/coronavirus https://www.gov.uk/government/collections/guidance-for-schools-coronavirus-covid-19

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Document control

FieldValue
VersionDec 2025
OwnerDirector of Operations
Statuslive
Source file1. All Company/Business Continuity Management - Dec 2025.pdf