INVESTMENT POLICY STATEMENT

  1. Introduction

    1. The Stock Exchange Dramatic and Operatic Society (Sedos) is a charitable incorporated organisation (CIO), whose purpose is (i) to educate the public in the fields of dramatic and musical theatre and to further development of public appreciation of and taste in the said fields and (ii) to give the opportunity for persons interested in the fields of dramatic and musical theatre to participate whether on or off stage in theatrical productions of high quality. 
    2. Under article 4(5) of the Sedos constitution, Sedos has the power to “deposit or invest funds, employ a professional fund manager and arrange for the investments or other property of the CIO to be held in the name of a nominee, in the same manner and subject to the same conditions as the trustees of a trust are permitted to do by the Trustee Act 2000”.
    3. Sedos has an annual income from ticket sales, programme sales, membership subscriptions, and fees for classes and workshops of approximately £100,000 to £140,000. Annual expenditure is approximately £120,000 per annum, allowing for a small annual surplus of approximately £10,000 per annum. Any annual surplus of income over expenditure is applied to the Sedos reserve capital held in an account with Lloyds Bank.
    4. In addition, Sedos has been the beneficiary of the transfer of reserve capital from its predecessor charity vehicle, registered charity 1099443 (‘Old Sedos’). The transfer of funds from Old Sedos occurred when Sedos decided to restructure itself as a CIO. The funds from Old Sedos were made up of corporate charitable donations and an individual legacy request Old Sedos transferred approximately £536,000 to Sedos and these funds have been held as Sedos reserves in a bank account with Lloyds Bank, for any unforeseen expenditure and to support Sedos strategic objective of securing long term rehearsal and performance spaces.
    5. Sedos currently holds no reserves outside the funds held in the Lloyds Bank Account.
    6. The Board of Sedos has determined that the sum of £300,000 should be invested in Rathbones Active Income and Growth Fund. These funds should be invested to grow at least in line with inflation. They are being invested to achieve a return so that they can further Sedos charitable aims. The board has determined that the investment with Rathbones Active Income and Growth Fund should be a financial investment and should achieve the best financial return within the level of risk considered to be acceptable.
    7. The Board of Sedos have determined that the balance of reserves within the Lloyds Bank Account will be transferred to Charity Bank where such funds will be invested to directly further the aims of other charitable organisations, as well as achieving a financial return for Sedos. The balance of funds held in the Lloyds Bank Account will be used for the day to day running of Sedos to achieve its charitable purpose.
    8. The Board of Sedos review investment decisions at regular meetings. Responsibility for day- to day investment management will lie with an authorised professional investment manager regulated by the FCA. This will be on a discretionary basis.
  2. Investment Objectives

    1. The Board of Sedos seeks to produce the best financial return within an acceptable, medium level of risk.
    2. The investment objective for the long term investments is to generate a return in excess of inflation.
    3. The investment objective for the short term is to preserve the capital value with a medium level of risk. Assets should be readily available to meet unanticipated cash flow requirements, as well as the anticipated capital expenditure to support Sedos strategic objective of securing long term rehearsal and performance spaces, when such spaces become available.
    4. The Board of Sedos would like to achieve a targeted return of CPI +3% in order to grow assets above inflation.
  3. Risk

    1. Attitude to Risk Sedos is reliant on legacies and on donations for its activities. Investment assets are held as reserves.

      The key risk to the long term reserves is inflation and the assets should be invested to mitigate this risk over the long term. The Board of Sedos understand that this is likely to mean that investment will be concentrated in real assets and that the capital value will fluctuate. It is recognised that in order to achieve the desired growth of the assets, a medium level of risk will be necessary. The Board of Sedos is comfortable with this. The focus of investment should include consideration for lowering volatility.

    2. Assets

      Sedos assets can be invested widely and should be diversified by asset class and by security. Asset classes could include cash, bonds, equities, property, hedge funds, structured products, private equity, commodities and any other asset that is deemed suitable for Sedos.

    3. Currency

      The base currency of the investment portfolio is Sterling.

  4. Liquidity Requirements

    1. Income from the long term investments will be re-invested. If there is a shortfall in income outside the investments, the Board may decide to draw down some of the capital, but this is not expected to be a regular occurrence.
  5. Time Horizon

    1. Sedos expects to hold investments for a long term time horizon of 6 to 10 years.
  6. Investment Policy

    1. Sedos has adopted an investment policy to ensure that its investments do not conflict with its aims.
    2. As such, Sedos wishes to avoid investments in any companies with a poor environmental record (e.g., recent cautions or convictions for pollution) or in companies who have been sanctioned for human rights abuses.
  7. Management, Reporting and Monitoring

    1. Sedos has appointed a professional investment management firm, Rathbones, to manage the assets on a discretionary basis, in line with this investment policy. The Board of Sedos has nominated a list of authorised signatories, two of which are required to sign instructions to Rathbones.
    2. Rathbones will provide the following information on a quarterly basis: valuation of investments and transaction report. Rathbones will also provide an annual report.
    3. The Board of Sedos has responsibility for agreeing strategy and monitoring the investment assets. The Board of Sedos will review the information provided by Rathbones at their meetings. Rathbones will be required to present in person to the Board of Sedos on an annual basis.
    4. Performance of the investments will be measured against inflation +3% after fees over any rolling five year period.
  8. Approval and Review

    This Investment Policy Statement was prepared by the Board of Sedos to provide a framework for the management of its investments. It will be reviewed on an annual basis to ensure continuing appropriateness.

Approved: 24 February 2020


CONFLICT OF INTEREST POLICY

  1. INTRODUCTION

    1. This policy applies to trustees of the Stock Exchange Dramatic and Operatic Society (‘Sedos Trustees’) and sets out guidelines and procedures for identifying, monitoring and managing actual and potential conflicts of interest by Sedos Trustees.

    2. In the most general sense, the relevant law says that a Sedos Trustee cannot:

      1. benefit from an arrangement or transaction entered into by Sedos, if before the arrangement or transaction was entered into, the Sedos Trustee did not disclose their interest to all of the other Sedos Trustees; and
      2. accept a benefit from a third party conferred by reason of being a Sedos Trustee or by reason of doing (or not doing) anything in their role as a Sedos Trustee unless the acceptance of the benefit cannot reasonably be regarded as likely to give rise to a conflict of interest.
    3. If there is an actual or potential conflict of interest for a Sedos Trustee, it needs to be declared and dealt with in accordance with this policy, the Sedos Constitution and the relevant law. In addition, if it is determined that a transaction gives rise to a conflict, then the transaction needs to be authorised by the Sedos Trustees before that transaction proceeds. It should be noted that this does not apply to a reimbursement by Sedos to a Sedos Trustee (or payment by a Sedos Trustee out of Sedos’ funds) of expenses properly incurred by the Sedos Trustee in the performance of any of Sedos’ functions.

    4. In this policy, references to:

      1. "conflicts" or "conflicts of interest" include actual and/or potential conflicts of interest and/or duty;

      2. persons who are "connected" with a charity trustee means:

        1. a child, stepchild, grandchild, parent, brother or sister of a charity trustee;
        2. the spouse, unmarried partner or civil partner of a charity trustee or of any person falling within paragraph (i) above;
        3. any person who is in a business partnership with a charity trustee or any person who is in a business partnership with any person falling within paragraph (i) or (ii) above; and
        4. any company, business, trust or organisation in which a charity trustee (or any other person connected to them) has an interest as a beneficiary or through ownership, control or influence.

        If in doubt about whether a person is connected, a Sedos Trustee should seek external advice from a solicitor or other person qualified to advise on the matter; and

      3. "benefit" includes any payment or material benefit (including property, loans, goods and services), other than reasonable out of pocket expenses.

    5. The Sedos Constitution (at Section 7) sets out some procedures in relation to conflicts of interest. This policy should be read in conjunction with the Sedos Constitution and relevant provisions in the Sedos Constitution take precedence over this policy. 

  2. THE PURPOSE OF THIS POLICY

    1. Sedos Trustees have a personal duty to act in the best interests of Sedos. This means that they must not place themselves in a position where they have, or may have, a direct or indirect interest that conflicts with their duties as a Sedos Trustee and must not profit from their position as a Sedos Trustee.  The Charities Act 2011 and Charitable Incorporated Organisations (General) Regulations 2012 (SI 2012/3012) also set out some specific duties and responsibilities in relation to conflicts of interest.
    2. Conflicts of interest can inhibit open discussions and may result in Sedos Trustees taking irrelevant considerations into account or making decisions that are not in Sedos’ best interests. They can also damage the reputation of Sedos if it appears that Sedos Trustees are influenced by personal interests or loyalties. All Sedos Trustees must therefore be alert to the possibility that they, or other Sedos Trustees, could be affected by a conflict of interests. 
    3. The procedures in this policy will enable Sedos Trustees to identify and manage conflicts of interest so that they can ensure that conflicts do not prevent them from making decisions in the best interest of Sedos. The policy will also help protect Sedos and the Sedos Trustees from any appearance of impropriety in cases where conflicts of interest arise.
  3. IDENTIFYING CONFLICTS OF INTEREST

    1. A conflict of interest is any situation in which a Sedos Trustee's direct or indirect interests could, or could be seen to, prevent them from making a decision only in the best interests of Sedos.

    2. Conflicts of interest may arise:

      1. where a Sedos Trustee (or a person connected to them) stands to obtain a benefit from Sedos; or
      2. where a Sedos Trustee has a duty of loyalty to a third party that conflicts with their duty to Sedos.
    3. When considering if they have a conflict of interest, a Sedos Trustee must be aware of the following principles:

      1. a conflict of interest exists if there is a possibility that the Sedos Trustee's personal interest could influence their decision-making, even if the Sedos Trustee's decision-making is not in fact adversely affected by the conflict. A reasonable perception that a conflict of interest exists can be enough for a Sedos Trustee to be in breach of their duties; and
      2. the interest that gives rise to a conflict may be direct or indirect and, in particular, a conflict may relate to the interests of someone who is connected to a Sedos Trustee as well as to their own personal interests.
    4. It is impossible to set out all situations which may result in a conflict, but they may include:

      1. selling, loaning or leasing Sedos’ assets to a Sedos Trustee (or a connected person);

      2. acquiring, borrowing or leasing assets from a Sedos Trustee (or a connected person);

      3. paying a Sedos Trustee for carrying out:

        1. their role as Sedos Trustee,
        2. a separate paid post at Sedos (even if they have resigned as a Sedos Trustee); 
      4. paying a Sedos Trustee (or a connected person) for providing a service and/or goods to Sedos; 

      5. employing a person connected to a Sedos Trustee at Sedos;

      6. making a grant to a Sedos Trustee (or a connected person);

      7. when a Sedos Trustee (or a connected person) owes a legal obligation or duty towards another organisation or person (for example, an employer or another charity of which they are a charity trustee) that conflicts with the Sedos Trustee's duty to Sedos;

      8. when a Sedos Trustee has a personal sense of loyalty to another organisation or person that conflicts with their loyalty to Sedos; and

      9. when a Sedos Trustee has religious or political views that could interfere with their ability to make decisions in the interest of Sedos.

  4. PROCEDURE FOR DECLARING INTERESTS

    1. All Sedos Trustees have a personal responsibility to declare any interest that might reasonably be regarded as potentially giving rise to a conflict.

    2. On appointment, all Sedos Trustees must complete a declaration of interests form:

      1. listing any personal interests, business interests or other direct or indirect interests that might potentially give rise to a conflict of interests;
      2. listing any interests of connected persons that may potentially give rise to a conflict of interest;
      3. declaring any gifts or hospitality received or offered to them in their capacity as charity trustee;
      4. confirming that they are not aware of any conflict, other than those already disclosed, that exists between their role and their personal circumstances or other interests;
      5. confirming that they will update the form annually, or sooner if any changes occur; and
      6. confirming that they will declare any conflict that arises in the future.
    3. The information provided by Sedos Trustees must be recorded in a register of Sedos Trustees' interests (the ‘Conflicts’ Register’). At least once in every 12-month period, all Sedos Trustees must review the information relating to them contained in the Conflicts’ Register and declare that the information is correct or make a further declaration if necessary. 

    4. It is for individual Sedos Trustees to decide which matters to declare but, if in doubt, they should make a declaration. 

    5. The information provided by Sedos Trustees will be processed in accordance with any prevailing Sedos Privacy Policy, and in any event with data protection principles as set out in the General Data Protection Regulation and the Data Protection Act 2018. Data will be processed only for the purposes set out in this policy and not for any other purpose.

  5. MAINTAINING THE CONFLICTS’ REGISTER 

    1. The Secretary to the Sedos Trustees will be responsible for maintaining the Conflicts’ Register and will:

      1. record in the Conflicts’ Register all conflicts, interests, gifts and hospitality declared by Sedos Trustees; and
      2. circulate amendments or additions to the Conflicts’ Register (if any) to the Sedos Trustees at the start of each Sedos Trustee meeting.
    2. The Conflicts’ Register will be available for inspection by any Sedos Trustee.

  6. DECLARATION OF INTERESTS BY PROSPECTIVE SEDOS TRUSTEES

    1. Before a prospective Sedos Trustee is appointed, they must be asked to declare any direct or indirect interests they have that might give rise to a conflict of interests.
    2. If the Sedos Trustees consider it likely that the prospective Sedos Trustee will be subject to serious or frequent conflicts of interest, the Sedos Trustees should consider whether it is appropriate to proceed with the appointment.
  7. PROCESS FOR DECLARING CONFLICTS

    1. The first item on the agenda of each Sedos Trustee meeting will be a standing item requiring all Sedos Trustees attending the meeting to declare any conflicts of interest relating to the matters to be discussed at the meeting.
    2. If a Sedos Trustee considers that they have an actual or potential conflict, they must inform the Chair as soon as possible and always before any discussion of the relevant matter. The declaration must specify the nature and extent of any direct or indirect interest that gives rise to the conflict.
    3. If a Sedos Trustee is aware that another Sedos Trustee has an actual or potential conflict that has not been declared, they must notify the Chair OR the other Sedos Trustees.
    4. If the Chair is declaring a conflict, they must inform the Vice-Chair OR the other Sedos Trustees.
    5. If a Sedos Trustee is uncertain whether or not they are conflicted, they should make a declaration to the Chair OR the other Sedos Trustees.  
    6. The Secretary to the Sedos Trustees must note all conflicts declared in the minutes of the meeting in which they were declared or, if not declared in a meeting, in the minutes of the next Sedos Trustee meeting.
  8. PROCEDURE FOR ASSESSING CONFLICTS AT MEETINGS

    1. At the start of each meeting of Sedos Trustees:

      1. the Chair must inform the other Sedos Trustees and the Secretary to Sedos of any conflict of interest that has been declared by a Sedos Trustee that relates to the business to be discussed at the meeting; and
      2. the Secretary to Sedos will circulate any amendments or additions to the Conflicts’ Register made since the last meeting of Sedos Trustees.
    2. The way in which conflicts are dealt with will depend on the nature and extent of the conflict. The non-conflicted Sedos Trustees must therefore:

      1. assess the nature and extent of the conflict;
      2. assess the risk or threat to decision-making by the Sedos Trustees;
      3. decide whether the conflict is serious (for example, the conflict is acute or extensive, will or may be seen to prevent the Sedos Trustees from making decisions in the best interests of Sedos, relates to a significant decision or risks significantly damaging Sedos' reputation); and
      4. decide what steps to take to handle the conflict.

      When considering the conflict, the Sedos Trustees must take all relevant factors into account, make decisions only in the best interests of Sedos and always protect Sedos' reputation.

    3. The conflicted Sedos Trustee must not take part in any discussion or decision about the conflict and how to handle it and will not be counted in the quorum for that part of the meeting.

    4. The non-conflicted Sedos Trustees must consider whether it is necessary to seek legal advice on whether the conflict is serious and/or on how to manage the conflict declared.

  9. AUTHORISED CONFLICTS OF INTEREST

    1. A Sedos Trustee's duty to avoid a conflict of interest does not apply if, and to the extent that, the conflict of interest is authorised by any of the following:

      1. an express provision in the Sedos Constitution;

      2. a statutory provision, such as the powers in the Charities Act 2011 to:

        1. pay a charity trustee (or a connected person) for providing services to the charity (sections 185 to 188); or
        2. take out and pay premiums for trustee indemnity insurance (section 189); or
        3. the Charity Commission or the court.
    2. In each case, the Sedos Trustee must always follow any conditions that apply to the authorisation.

  10. PROCEDURES FOR MANAGING CONFLICTS

    1. If the conflict arises owing to a financial transaction between Sedos and a Sedos Trustee (or a connected person), or because a Sedos Trustee (or a connected person) will or may obtain a benefit from Sedos:

      1. any potential or proposed benefit must be authorised in advance; and

      2. the conflicted Sedos Trustee must:

        1. withdraw from all discussions and decisions in relation to the matter; and
        2. not be counted in the quorum for that part of the meeting.
    2. If the non-conflicted Sedos Trustees decide that a conflict is serious, they must consider:

      1. securing the conflicted Sedos Trustee's resignation and/or appointing a new Sedos Trustee who is not conflicted;
      2. not pursuing the course of action that gives rise to the conflict or proceeding in a different way so that the conflict does not arise;
      3. seeking independent, expert advice about how to handle the conflict; and
      4. asking the Charity Commission for guidance.
    3. If a conflict is not serious, the non-conflicted Sedos Trustees must decide what procedures and level of participation by the conflicted Sedos Trustee are appropriate. A number of steps can be taken to deal with the conflict, including:

      1. requiring the conflicted Sedos Trustee to withdraw from the meeting for the relevant item and not to be counted in the quorum for that part of the meeting;
      2. allowing the conflicted Sedos Trustee to remain in the meeting for the relevant item to take part in the discussion, but requiring them to withdraw from the meeting during decision-making and to have no right to vote on the matter; or 
      3. appointing a new, non-conflicted Sedos Trustee.
    4. If the non-conflicted Sedos Trustees decide that the conflict is low risk (in that it will not prevent the conflicted Sedos Trustee from making decisions in the best interests of Sedos), they may agree that the conflicted Sedos Trustee may continue to participate in discussions and the decision-making process.

    5. The Chair must inform the conflicted Sedos Trustee of the non-conflicted Sedos Trustees' decision about how to manage the conflict.

    6. The minutes of the relevant meeting must include a record of the nature and extent of the conflict, an outline of the discussion and the actions taken to manage the conflict.

    7. Where a Sedos Trustee or a connected person receives a payment or benefit from Sedos, this must be reported in the annual accounts in accordance with the current Statement of Recommended Practice for accounting by charities (Charities SORP).

  11. ADVISERS AND CONFLICTS

    1. Before appointing any advisers to Sedos, the Sedos Trustees must consider whether the adviser has, or may be seen to have, any actual or potential conflict with the interests of Sedos.
    2. Although most advisers will be members of professional or regulatory bodies and will be required to comply with the relevant professional guidelines, some advisers will not be members of such bodies. The terms of appointment of those advisers may therefore need to be modified to include specific provisions relating to conflicts:  
      1. an obligation to inform the Sedos Trustees if any circumstances arise in which they are or may be conflicted; and 
      2. an obligation to address any conflicts that arise in the work they do for the Sedos Trustees.
  12. TRAINING

    All newly appointed Sedos Trustees must receive training on this policy and on identifying situations that may result in a conflict and ways in which conflicts can be managed in practice. In addition, charity trustees must be familiar with the principles contained in the Charity Commission's guidance on conflicts.

  13. MONITORING, ENFORCING AND REVIEWING THIS POLICY

    Any Sedos Trustee who becomes aware of a breach of this policy must report it to the Secretary to the Sedos Trustees or the Chair as soon as possible. This policy shall be enforced by the Sedos Trustees as a body. This policy shall be made available to members of Sedos via the Sedos website. This policy will be reviewed annually in line with industry best practice standards and all relevant legislation and regulations.

Approved: 14 July 2020


COVID-19 HEALTH AND SAFETY POLICY

A. INTRODUCTION

This policy sets out:

  • Sedos’ commitment to ensuring all of its shows and other activities are conducted in a COVID-19 secure manner;
  • The COVID-19 related requirements that must be complied with in respect of any rehearsals, shows, classes, meetings or other activities conducted by Sedos members in the furtherance of Sedos’ aims (“Sedos Activities”);
  • The requirements of the Sedos ‘Track and Trace’ record; and
  • The specific plan for people that need to self-isolate and/or are identified as symptomatic.

This policy should be read in conjunction with the prevailing government guidance on COVID-19 for professional and non-professional performing arts organizations as it is updated from time to time (the “Guidance”). The links to the Guidance can be found at the end of this policy.

Responsibility for compliance with this policy shall rest with the Management Committee (led by the COVID Compliance Officer) under the supervision and guidance of the Board of Trustees. The Management Committee and COVID Compliance Officer may delegate day-to-day responsibility for compliance with this policy in respect of a specific Sedos Activity to a Session Leader in accordance with section E of this policy but shall regularly monitor that Sedos Activity to ensure compliance is being met and if it is not shall either take steps to ensure compliance or stop the Sedos Activity from proceeding. 

The COVID Compliance Officer shall be nominated by the Management Committee and at the date of this policy is:

Adam Coppard covid@sedos.co.uk

The COVID Compliance Officer shall be the first person contacted in the case of a COVID-19 outbreak, in line with section F of this policy.

B. SEDOS COMMITMENT

Sedos is committed to:

  • maintaining and protecting the health, safety and welfare of its members and the audiences of the shows that it performs;
  • ensuring that any Sedos Activities are conducted in a COVID-19 secure manner and, at a minimum, in accordance with this policy and the Guidance;
  • ensuring that any venues or locations at which Sedos Activities are undertaken are COVID-19 Secure Venues and, at a minimum, comply with this policy, the Guidance and any other government guidance relevant to that venue; and
  • ensuring that its members, volunteers and non-professionals are afforded the same level of protection to their health and safety as employees and the self-employed. 

C. RISK ASSESSMENT

The COVID-19 risk assessment (attached at Annex 1) shall be reviewed and, if necessary, updated on a regular basis and the risk mitigating actions set out therein shall be put into practice by the Management Committee. A copy of the risk assessment and this policy shall be accessible on the Sedos website. 

D. VENUES

Sedos Activities are conducted at a number of venues. The two venues where Sedos Activities are most often conducted and over which Sedos has the most control with respect to COVID-19 security are Brewers Hall Gardens (“BHG”) and the Bridewell Theatre. The Management Committee, under the supervision of the Board of Trustees shall ensure that:

  • BHG is maintained as a COVID-19 Secure Venue;
  • the Bridewell Theatre and any other space where Sedos Activities take place are COVID-19 Secure Venues for so long as they are being used by Sedos; 
  • this policy and a signed version of this notice are posted on notice boards in BHG and on the Sedos website; and
  • clear guidance on social distancing and hygiene is provided to audiences before arrival at any performance, for example by email when purchasing tickets, and on any digital marketing and websites.

BHG

For so long as there is no proven effective vaccine for COVID-19 and transmission of COVID-19 remains a risk, no Sedos Activities of any kind shall occur in BHG unless such Sedos Activities comply with the terms of this policy and the prevailing Guidance (other than any activities by suitable authorised persons that are required to make BHG a COVID-19 Secure Venue or otherwise to bring BHG in compliance with this policy or any other HSE policy or law). The maximum number of participants allowed in each space in BHG shall be set by the COVID Compliance Officer from time to time taking into account the prevailing Guidance. On the basis of maintaining social distancing of 2m at all times this shall be a maximum of:

  • 14 people for Space 1;
  • 10 people for Space 2;
  • 4 people for the build space (assuming face masks are always used);
  • 1 person for kitchen;
  • 2 people for sewing room (assuming face masks are used when there are two);
  • Props and costume sections only to be used by the production team member(s) responsible for props/costume.

Bridewell Theatre

For so long as there is no proven effective vaccine for COVID-19 and transmission of COVID-19 remains a risk, no Sedos Activities of any kind shall occur in the Bridewell Theatre unless such Sedos Activities comply with the terms of this policy, any policy of the Bridewell Theatre and the prevailing Guidance. 

Other Venues and Locations

Before any Sedos Activities are conducted at venues other than BHG or the Bridewell Theatre, due diligence shall be done to ensure that such venue is a Covid-19 Secure Venue. Any Sedos Activities at such venue shall comply with the terms of this policy, any policy of that venue and the prevailing Guidance.

E. ACTIVITY BY ACTIVITY RISK ASSESSMENT AND COMPLIANCE

Session Leaders

Whenever SEDOS undertakes a Sedos Activity, a separate COVID risk assessment shall be conducted for that Sedos Activity. Whilst the Management Committee will retain overall responsibility for ensuring that all Sedos Activities comply with this policy and the Guidance, a “Session Leader” shall be designated for each Sedos Activity who is delegated responsibility for ensuring the Sedos Activity complies with this policy and the Guidance. The Session Leader shall be a person (or persons) who is responsible for planning and conducting the Sedos Activity and is intended to be present at all or a majority of the in-person meetings for the Sedos Activity. For example, the director or producer of the relevant show or the person running the particular Sedos class.  

Activity Plan

Before commencement of the Sedos Activity, the Session Leader shall meet with the COVID Compliance Officer or other suitable qualified members of the Management Committee responsible for policy compliance in order to:

  • demonstrate they have read and understood this policy and the Guidance; and
  • set out and agree a plan for ensuring their particular activity will comply with this policy and the Guidance (an “Activity Plan”).

If the Management Committee is satisfied that the Activity Plan properly mitigates any general and specific risks and that the Session Leader can reasonably ensure compliance with this policy and the Activity Plan by participants, the Sedos Activity may proceed in accordance with this policy and the Activity Plan. 

In considering any Activity Plan where the Guidelines and this policy cannot be followed in full, the Management Committee shall consider whether that Sedos Activity needs to continue, and if so, take any additional actions possible to reduce the risk of transmission between participants and audiences.

The Session Leader, with the support of the Management Committee shall be responsible for ensuring that all participants comply with this policy and the Activity Plan. If the relevant Sedos Activity is a show, there may be separate Activity Plans for the rehearsal period and the performance period and the rehearsal period may proceed before the Activity Plan for the performances has been discussed and agreed.

The Session Leader shall also ensure that ahead of commencement of the Sedos Activity, each participant receives the short form “Do’s and Don’ts” list set out in Annex 2. Copies of this list shall also be posted separately and prominently in BHG. 

Specific Considerations to take into account for an Activity Plan

In developing and implementing an Activity Plan the Management Committee and the Session Leader should consider the following (on a non-exclusive basis):

  • Maintaining social distancing wherever possible and reducing as far as possible any time that individuals are not able to maintain social distancing;

  • Limiting the number of performers as far as possible including conducting rehearsals and training in smaller fixed teams wherever possible;

  • Limiting the number of audience members, noting that capacity should be maintained at a level that allows social distancing to be maintained;

  • Limiting the duration of social interaction opportunities at break times as far as possible including:

    • Staggering break times and using safe and separate outside areas for breaks;
    • Encouraging participants to remain on-site during breaks and, when not possible, maintaining social distancing while off-site;
  • Encouraging participants to bring as few personal items with them as possible;

  • Taking steps to encourage audiences to support the overall safety of the event, including discouraging activities which can create aerosol (such as shouting, chanting and singing along), seating individuals rather than allowing them to stand (to help maintain social distancing);

  • Providing space for performers and other attendees to be socially distanced from each other and from any audience, production team members or other individuals, wherever possible during training, rehearsal, pre-production, performance and any other form of performing arts activity;

  • Working outdoors where possible. Where this is not possible, ensuring all rehearsal, training and performance areas, with particular regard to indoor and covered areas, have maximum ventilation whenever staff or audiences are present;

  • Organising and designing auditions, rehearsals, training and performance to avoid situations where performers cannot socially distance, wherever feasible;

  • Adapting live performing arts to ensure they are safe. If that is not possible, consider the use of technology solutions to reduce interactions and ensure social distancing (for example for auditions, rehearsals, production meetings, training and performance);

  • Using floor tape or paint to mark areas to help people maintain social distance, where possible;

  • Learning lines or parts in advance to avoid carrying scripts in rehearsal;

  • If performers are likely to spit during their performance, Session Leaders should consider additional mitigations such the use of face coverings or screens;

  • Performers attending rehearsals and performances only when required for their part and changing the call schedules so that only those required are on-site;

  • Considering contingency plans if a key performer or other participant becomes unable to participate in-person due to becoming symptomatic;

  • Where an individual is operating on a peripatetic basis, such as a teacher, director or choreographer, and operating across multiple groups or individuals: 

    • Maintaining distancing requirements with each group; 
    • Avoiding situations where distancing requirement is broken, for example demonstrating partnering work in dancing; and
    • Making efforts to reduce the number of groups interacted with and locations worked in, to reduce the number of contacts made;
  • Take steps to minimise the risk of transmission playing in music groups including:

    • Observing social distancing at all times whilst playing.
    • Using back-to-back or side-to-side positioning (rather than face-to-face) or screens or barriers whenever possible.
    • Playing outdoors wherever possible.
    • If playing indoors, limiting the numbers to account for ventilation of the space and the ability to social distance.
  • Structuring auditions in a safe way including:

    • Self-taping or online auditions to reduce numbers on-site;
    • Removing waiting rooms where it is not possible to facilitate social distancing, asking people not to arrive ahead of their allocated time slot, and providing clear instruction not to congregate in other areas if waiting;
    • Using screens to create a physical barrier between people, for example between casting team or accompanist and candidates;
    • Considering how to appropriately protect any supporting creative team, for example by using screens or ensuring social distancing can be maintained;
    • Considering the needs of disabled and deaf workers and participants in making adjustments to casting and auditions management;
  • Taking steps to reduce transmission and maintain social distancing where possible whilst designing and constructing the set;

  • Taking steps to reduce transmission through contact with objects such as props including:

    • Encouraging increased handwashing;
    • Avoiding sharing personal items such as phones, chargers, pens, and asking owners take responsibility for regularly disinfecting their own personal equipment;
    • Avoiding sharing professional equipment, music scores, parts and scripts wherever possible;
    • If equipment has to be shared, regularly disinfecting it and always between users;
    • Cleaning hire equipment, tools or other equipment on arrival and before first use;
    • Creating picking-up and dropping-off collection points where possible, rather than passing equipment such as props, scripts, scores and mics hand-to-hand.

The following are Activity Plan considerations specific to show performances:

  • Considering contingency plans if a key performer or other participant becomes unable to participate in-person due to becoming symptomatic;

  • Taking steps to minimise transmission and maintain social distancing before, during and after live performances including:

    • Conducting a specific risk assessment for each premises or venue and the proposed activities to identify: 

      • The number of people that can reasonably follow social distancing within the venue or premises, taking into account total space,   equipment as well as likely constraints (toilets and washrooms) and pinch points; 
      • The ventilation rates that can be applied to the premises or venue and whether this can be adjusted sufficiently to deliver a safe environment for all those due to attend at any time (performers, producers, support teams and audience combined); 
      • Which activities can be undertaken and which spaces can be used with specific measures to ensure social distancing and maintain cleaning;
    • Limiting ticket sales to a volume which ensures social distancing can be maintained; 

    • For performances or events where there is no ticketing, considering using other communications approaches, coupled with stewarding, to manage the numbers attending;

    • Setting appropriate limits for the number of people in the venue or on the premises, overall and in any particular congestion areas, for example doorways between outside and inside spaces;

    • Enabling a booking/seating system or other approaches to manage demand of spaces, and to record those attending, including their seating position which can be provided for contact tracing purposes in the event of a case of Covid-19 in a participant;

  • Considering using available spaces outdoors for performances with a live audience in attendance and if so considering

    • The guidance on delivering outdoor events, particularly where such performances are not typical to their operations;
    • Consulting with the relevant authorities and seeking specialist advice to best evaluate impact, developing mitigating strategies and coordinating relevant external agencies if required;
    • The expected interactions among participants occurring during the event and implementing sufficient controls to ensure social distancing is maintained;
    • Discouraging or avoiding activities or features that are likely to encourage audience behaviors increasing transmission risk;
  • Considering the expected interactions amongst audience members and making sure sufficient controls are in place to maintain social distancing, for example providing clear communication, demarcating spaces, using sufficient ushers;

  • Considering the particular needs of disabled audiences when making adjustments to venues or premises, and communicating these appropriately before any performance as well as when in the venue or premises;

  • Considering how front of house and back of house teams will operate during live performances, and between performers, crew members and audience members including considering;

    • Creating front of house and back of house zones with people operating exclusively within each zone, where possible;
    • Ensuring that members of fixed teams are particularly careful to maintain social distancing when interacting with audience members and others front of house and minimise time spent doing so;
    • Identifying any roles that typically operate both front of house and back of house, and minimising these where possible;
    • Identifying any roles that interact with audiences and manage transmission risk appropriately;
    • Minimising interaction of back of house staff with the audience;
  • Considering the measures of the venue to maintain social distancing wherever possible when people move around the site, premises or venue during performances including queuing for tickets and the toilets, bar areas;

  • Considering seating arrangements for audiences in a way which ensures social distancing between individuals or groups in line with the Guidance including:

    • Encouraging audience members not to bring bags and coats into auditoria where possible to reduce clutter at seats;
    • Seating and space for those requiring disabled seating or wheelchair space should be considered within the social distancing arrangements with due regard to accessibility responsibilities under the Equality Act 2010;
    • Having clearly designated positions from which site, premises or venue staff can provide advice or assistance to guests whilst maintaining social distance;
    • Considering the needs of disabled audience members, for example access to captioning or audio description services, when managing seating;
  • Considering how guidance on social distancing and hygiene will be delivered to audience members including before arrival, for example by email when purchasing tickets, and on any digital marketing and websites and at the venue itself;

  • Considering steps to minimise the risk of transmission in changing rooms including:

    • Ensuring they are kept clean and clear of personal items and that social distancing can be achieved as much as possible;
    • Introducing enhanced cleaning of all facilities regularly during the day and at the end of the day.
    • For additional reassurance, providing cleaning materials and hand sanitiser for use at touch points.
    • Providing additional signposting in these areas to maintain social distancing.
    • Considering creating additional dressing rooms in order to minimise contact between performers.
    • Where dressing rooms are shared, minimise the number of objects in the room that could be shared between performers;
  • Considering steps to reduce transmission and maintain social distancing where possible whilst managing sound and lighting including:

    • Creating a screen around sound and lighting desks to create a barrier which aerosols do not pass through between the sound team and audience or other crew;
    • Where the sound desk is positioned close to audience seating, consider leaving empty the closest row of seats;
    • Regularly cleaning desks, for example, sound, lighting, mics and battery packs;
  • Considering steps to reduce transmission and maintain social distancing where possible whilst managing the stage and back-stage including:

    • Restricting workers allowed back-stage and on-stage to those who are essential;
    • Not permitting visitors back-stage;
    • Considering how wings can be used to allow for the minimum possible interaction between people, for example one-way systems, dedicated wings for stage managers and dressers;
    • Reconfiguring back-stage to introduce one-way systems and use of green rooms and crew rooms by fixed teams;
    • Limiting prop handling to the minimum possible number of people and clean after every performance, and where possible between uses if handled by different people;
    • Limiting handling of key props on set to a dedicated crew member and relevant cast;
  • Considering the set-up of the band to reduce risk of working in band areas.

  • Considering costume quick changes and other costume change arrangements to reduce transmission and maintain social distancing where possible;

  • Considering steps to reduce transmission and maintain social distancing where possible whilst managing hair and make-up including:

    • asking performers to do their own hair and make-up where appropriate;
    • Where it is not possible for someone to do their own hair or makeup, following the government guidance on working in close contact settings where relevant; 
    • Limiting the time spent in a hair and make-up chair whenever possible;
    • Not sharing makeup equipment; Allocating own makeup kit, brushes, hair products and equipment to each cast member, to be sterilized each day and only used on them;
    • Increasing equipment and surface hygiene.

Accidents and other incidents

In the event of emergency or accident, safety shall take precedence over COVID-19 security. In an emergency people do not have to social distance if it would be unsafe.

F. PROCESS AFTER COVID OUTBREAK

Individuals who:

  • have tested positive for COVID-19;
  • have symptoms of COVID-19 (a high temperature, new and persistent cough or anosmia, however mild);
  • live in a household or are in a support bubble with someone who has symptoms; or
  • are advised to self-isolate as part of the government’s track and trace service,

shall not be permitted to take part in Sedos Activities until they have complied with this Section F (each an “Excluded Participant”).

If a participant becomes aware they are an Excluded Participant they should:

  • immediately inform the Session Leader(s) of any Sedos Activity they have taken part in over the previous 10 days;
  • self-isolate for at least 10 days from when their symptoms started OR if they are not experiencing symptoms but have tested positive for COVID-19 they should self-isolate for at least 10 days starting from the day the test was taken. If they have tested positive whilst not experiencing symptoms but develop symptoms during the isolation period, they should restart the 10 day isolation period from the day they develop symptoms;
  • if deemed necessary by the Management Committee, obtain the opinion of a doctor that it is safe to return to in-person activities before doing so.

If a Session Leader becomes or is made aware of a participant becoming an Excluded Participant they shall immediately:

  • inform the *COVID Compliance Officer** by email or phone (details in Section A);
  • inform all other participants in the Sedos Activity that a participant has become an Excluded Participant; and
  • suspend any in-person elements of the relevant Sedos Activity until the circumstances leading to that person becoming an Excluded Participant can be investigated by the COVID Compliance Officer.

Promptly thereafter the Session Leader shall meet with the COVID Compliance Officer and other relevant members of the Management Committee to discuss:

  • whether the Sedos Activity can continue; and
  • if it can continue, the terms on which it can continue, including investigating ways that the Excluded Participant can still participate from isolation.

The Management Committee shall reserve the right to suspend any Sedos Activity either temporarily or indefinitely if any participant in that Sedos Activity becomes an Excluded Participant.

G. TRACK AND TRACE

Sedos shall keep a temporary record of participants and audiences for any Sedos Activities for 21 days after the activity occurs, in a way that is manageable and accessible. Sedos shall assist NHS Test and Trace with requests for that data if needed. 

H. FACE COVERINGS

Face coverings should be used wherever possible in all Sedos Activities, including during breaks, downtimes and “off stage” times and especially in enclosed public spaces where social distancing may be difficult and where participants come into contact with people they do not normally meet. Consideration should always be given to whether the wearing of a face covering may inhibit communication with people who rely on lip reading, facial expressions and clear sound.

Approved: 21 November 2020

ANNEX 1 - COVID-19 Risk Assessment Register

Company name: Stock Exchange Dramatic and Operatic Society (“SEDOS”)

Completed by: Dan Saunders (Trustee) /Adam Coppard (Management Committee) (“Reviewers”)

Date of next review: January 2021 Date assessment was carried out: 12 September 2020

How was the risk assessment done? 

The Reviewers followed the advice at www.hse.gov.uk/simple-health-safety/risk/. 

To identify the hazards, they: 

  • considered the prevailing government guidance in force as at the date of the assessment; 
  • considered the primary premises that SEDOS operates in (being Brewers Hall Garden and the Bridewell Theatre) and factors that need to be assessed in those locations in order to make them COVID-19 Secure Venues;
  • reviewed the Bridewell Theatre COVID-19 Risk Assessment current as at the date of the assessment;
  • considered the needs of those with protected characteristics in making those locations in order to make them COVID-19 Secure Venues’
  • considered the range of activities that members of SEDOS engage in on a regular basis at SEDOS organised events; and
  • consulted with members of the Board of Trustees and Management Committee as elected representatives of the membership of SEDOS to obtain input of possible significant risks and the effect of any mitigations.

They noted what was already being done to control the risks and recorded any further actions required. They pinned a copy of the findings on a noticeboard in BHG and published the following risk assessment to the SEDOS website to encourage members to help put the actions into practice. 

The Reviewers (or other suitable members of the Board of Trustees and/or Management Committee members) will review the risk assessment whenever there are any significant changes to the government guidance or the apparent risk.

Where does the risk lie?

Who might be harmed and how?

What are we doing to control and mitigate the risks?

AREAS WITH INCREASED RISK OF TRANSMISSION OF COVID-19

Attending rehearsals, meetings, classes and other activities at Brewers Hall Garden (“BHG”)

Traditionally, most of SEDOS’ activities take place at BHG. These include:

  • rehearsals, 
  • classes such as Sedance, Simprov, SeYoga, SeChoir, 
  • set, prop and costume making;
  • storage of equipment, set and costume; and
  • production/committee meetings.

Continuing activities at BHG without taking measures to minimise the risk of the transmission of COVID-19 could lead to transmission among members and the people that they come into contact with.


Opportunities for additional ventilation in BHG are limited creating an increased risk in any tight spaces.

SEDOS has a COVID-19 policy drafted in line with prevailing government guidelines (the “Policy”) which must be complied with for any activity undertaken by SEDOS and its members, wherever it occurs. 


To promote and police compliance with this Policy in BHG, before any activity is undertaken in BHG a “Session Leader” is appointed who is delegated responsibility for ensuring compliance with the Policy.


Before commencement of the activity, the Session Leader is to meet with members of the Management Committee responsible for Policy compliance in order to:

  • demonstrate they have read and understood the Policy and any relevant government guidance applicable to their particular activity;
  • set out a plan for ensuring their particular activity will comply with the Policy (an “Activity Plan”).

If the Management Committee is satisfied that the Activity Plan properly mitigates any specific risks and that the Session Leader can reasonably ensure compliance with the Policy and the Activity Plan by participants, they may proceed with the activity in accordance with the Policy and the Activity Plan and shall be responsible for ensuring that all participants in the activity comply with the Policy and the Activity Plan.


Without limitation, any activity conducted in BHG shall:

  • adhere to the government guidance regarding non-professional theatre groups at all times;
  • employ appropriate social distancing for participants in line with the prevailing guidance; 
  • limit the number of participants as far as possible and always within maximum limits prescribed by the government guidance;
  • limit the duration of social interaction opportunities as far as possible;
  • use face masks wherever use of face masks does not materially prevent efficacy of the activity;
  • exclude any person that shows symptoms of COVID-19 or has either shown symptoms or been exposed to a person that has symptoms in the previous 14 days.

General mitigations measures employed within BHG include:

  • Hand sanitiser stations at key locations;
  • Toilet facilities with anti-bacterial cleaning supplies and single use/non-contact hand drying facilities;
  • Additional signage encouraging social distancing;
  • Additional signage encouraging good hygiene practices; 
  • Use of a ‘Track and Trace’ system; and
  • Regular cleaning of BHG by third party professional cleaners.

There are other specific limits and restrictions set out in the Policy. The relevant Activity Plan may have additional limits, restrictions and actions over and above what is set out in the Policy appropriate for that activity.


The Policy also includes an up to date plan in case there is a COVID-19 outbreak. 

Performing at the Bridewell Theatre (or any other performance venue)

As an amateur dramatics society, SEDOS performs up to 10 shows per year. Shows usually take place at the Bridewell Theatre although other venues are sometimes used.


Performing in a theatre includes the additional risks (as compared to the risks outlined for BHG above) in the following areas:

  • limited space backstage and in dressing rooms;
  • potential inability for performers to properly social distance as part of the performance;
  • the attendance of audience members; and
  • potential lack of adequate ventilation. 

All SEDOS performances must comply with the Policy and a specific Activity Plan that takes into account the increased risks associated with performing in the particular performance space with a live audience. 


Without limitation, performance activity conducted in the Bridewell Theatre or any other performance space will:

  • adhere to the government guidance regarding non-professional theatre groups at all times;
  • employ appropriate social distancing for both participants and audience members in line with the prevailing guidance; 
  • limit the number of performers and audience members to be within the maximum limits prescribed by the government guidance;
  • limit the number of audience members, noting that capacity should be maintained at a level that allows social distancing to be maintained;
  • limit the duration of performances as far as possible;
  • take steps to improve ventilation as far as possible and whenever possible, both through the use of mechanical systems and opening windows and doors;
  • take steps to encourage audiences to support the overall safety of the event, including discouraging activities which can create aerosol (such as shouting, chanting and singing along), seating individuals rather than allowing them to stand (to help maintain social distancing) and the other mitigations outlined in the government guidance; and
  • comply with any specific guidelines and policies of the relevant performance venue to the extent they exceed the requirements of the Policy and the Activity Plan.

Attending rehearsals, meetings, classes and other activities at any other venue other than Brewers Hall Gardens or the Bridewell Theatre

From time to time SEDOS activities are conducted at third party controlled locations. There is a risk that such locations may not employ the same COVID-19 standards set out in the Policy thus increasing the risk of transmission of COVID-19 among SEDOS members and audiences.

When choosing any third party controlled venue to conduct activities a separate assessment shall be made as to whether such venue complies with its own government mandated requirements as to COVID-19 security and as to whether the SEDOS activity can be conducted at that venue in adherence with the Policy and any Activity Plan. 

COVID-19 RELATED CONSIDERATIONS FOR THOSE WITH PROTECTED CHARACTERISTICS

Use of masks by participants

The additional use of masks may prevent hearing impaired audiences from using lip reading techniques to understand what is being said in meetings, rehearsals or performances.

Where possible separate, COVID-19 secure arrangements shall be made to ensure hearing impaired participants can fully participate in the activity and/or access the performance. This may include:

  • the preferred use of videoconferencing for any meetings even when in-person meeting would be COVID-19 secure;
  • sur or sub titles/sign language for performances; and/or
  • transparent face screens or masks being used instead of opaque masks.

Access to sanitation products by people with access issues

If improperly located, additional sanitation equipment may not be acceptable to those with access issues.

Due consideration is given to the location of hand sanitiser stations and toiletry products to ensure that there is easy access to those products by all people.

More information on managing risk: www.hse.gov.uk/simple-health-safety/risk/ 

ANNEX 2 – COVID-19 Do’s and Don’ts

DO – Socially distance (2m) at all times including during rehearsals and break times. 

DO – Wear a face mask at all times unless it is completely impractical to do so for the activity you are participating and always when you cannot adhere to 2m social distancing.

DO – Listen to and follow the instructions of your Session Leader with regard to COVID-19 security at all times.

DO – Change into rehearsal/dance/yoga clothes before coming to BHG where possible.

DO – Regularly sanitize and wash your hands.

DO – Follow all signage regarding COVID-19.

DO – Ensure you have been recorded in the SEDOS track and trace record . 

DON’T – Go into a space within BHG where you are not absolutely required to be.

DON’T – Share scripts, librettos, props or other equipment unless absolutely necessary and then, only when such equipment has been appropriately sanitised between use.

DON’T – bring any personal items into BHG that are not absolutely required for the activity you are attending for.

DON’T – Touch any equipment, set, props or surfaces that you do not need to touch.

DON’T – Spend any more time in BHG than is needed. This includes leaving BHG when your involvement in the activity has finished, even if the overall activity is still ongoing.

DON’T – Have more than one person at a time in the kitchen or any toilet.

DO IMMEDIATELY INFORM YOUR SESSION LEADER IF YOU:

have tested positive for COVID-19;

have symptoms of COVID-19 (a high temperature, new and persistent cough or anosmia, however mild);

live in a household or are in a support bubble with someone who has symptoms; or

are advised to self-isolate by a doctor or as part of the government’s track and trace service.

The full SEDOS COVID-19 Policy and Risk Assessment can be found on the Sedos website at https://sedos.co.uk/


Privacy Policy

Sedos respects your privacy and does not sell, rent or loan any identifiable information collected on this site. Any information that you give will be treated in a careful and secure manner. It will not be used in ways to which you have not consented.

This statement explains how we may collect and use information about you through our website. If you have any questions about our privacy policies, want to exercise your right to see a copy of the information that we hold about you, or think that information we hold about you may need to be corrected, please send an email to our data protection officer at dataprotection@sedos.co.uk.

We do not seek to identify individual visitors unless they volunteer their contact details through one of the forms on the site. Various forms on our site invite you to submit your contact details and other information about yourself or your organisation, or to send us emails which may, of course, also identify you. In each case, the purpose for which you are invited to give us information is clear and we also indicate which of the requested information is essential for the relevant purpose and which is optional - fields for essential information are marked with an asterisk. We will only use your details to send you information from Sedos that you have specifically requested to receive. If you no longer wish to receive such information, our emails contain a link that will allow you to change or terminate your subscription to our email alerting service. Alternatively, you can let us know your preferences by sending an email to webmaster@sedos.co.uk. We will not use your information for purposes that are not clear when you provide your details, and will not disclose it outside Sedos, except in very limited circumstances and only with your agreement or where we are legally obliged to do so.

Sedos strives to protect the security of information that you provide to Sedos, and will comply at all time with its statutory and any other obligations in this regard.