This document contains the following policies:
• Anti-bribery and anti-corruption policy
• Modern slavery policy
BlakerTech - Anti-bribery and anti-corruption policy
What is bribery?
This is the act of offering something of value to influence a decision leading to an ultimate business advantage or benefit.
To be more specific, it refers to offering, giving, asking, promising, agreeing, receiving something of value to influence a behaviour, action or decision.
BlakerTech employees must not take part or engage in any form of bribery as it is an illegal act.
This anti-bribery policy sets out the responsibilities of BlakerTech and everyone who works for us to observe and uphold our zero-tolerance position on bribery and corruption.
BlakerTech is committed to conducting business in an ethical and honest way and is dedicated to implementing and upholding systems and processes that guarantee bribery is prevented. BlakerTech does not tolerate acts of bribery and corrupt activities. We act professionally and fairly in all business dealings and relationships.
BlakerTech will respect and uphold all laws in relation to anti-bribery and corruption in all the jurisdictions in which we operate. We work and are bound to the laws of the UK, including the Bribery Act 2010, relating to our conduct both in the UK and overseas.
BlakerTech understands that bribery and corruption is not tolerated and punishable by up to ten years of imprisonment and a fine. If BlakerTech is found to have taken an active role in corrupt activities, we may be liable to an unlimited fine, face exclusion from tendering for public contracts, and receive negative public relations. With this in mind, we take our legal responsibilities very seriously.
Who this policy covers
This policy covers all employees and associated third parties:
- Agency staff
- Sister companies (and their employees)
- Any persons associated with us (including suppliers and third parties)
Any agreements or arrangements BlakerTech makes with a third party is subject to clear contractual terms including the requirement for the third party to comply with minimum acceptable standards and procedures relating to anti-bribery and corruption.
Kickbacks and facilitation payments
We understand facilitation payments are a form of bribery and we will not accept or make any form of facilitation payments of any kind.
Kickbacks are not tolerated at BlakerTech. We recognise that kickbacks are made in exchange for a business advantage or favour.
Gifts and hospitality
We accept appropriate gestures of goodwill and hospitality. However, the giving and receiving of gifts must meet the following requirements:
- It is appropriate to the situation or circumstance, e.g. a box of chocolates for Christmas and to thank the company for their help in completing a large project
- It is not made with the expectation that a return favour must be reciprocated
- It is not given to a key individual with the clear intention to influence them
- It must be given in a company name – not an individual
- It must not contain cash
- It complies with local law
- It is not made with the intention of influencing the third party to whom it is being given or to receive a business advantage of any kind
- It is not given in secret
- It is not above £100
On some occasions it may be inappropriate to decline an offer of a gift, e.g. when meeting with someone from another culture who may take offence if a gift is declined.
All gifts given and received are disclosed to our compliance manager – especially those from suppliers.
We ensure our employees read, understand and comply with the information contained in this policy and any training or other anti-bribery and corruption information given.
If any of our employees breach this policy, they will face disciplinary action and dismissal for gross misconduct. We have the right to terminate a contractual relationship with an employee if they breach this anti-bribery policy.
Raising a concern
If you believe there is bribery or corrupt activities taking place in connection with BlakerTech, please express your concern as early as possible. We would ask that you speak with our compliance manager, Robin Plater.
Political and charitable contributions
BlakerTech will not support any political parties by making improper donations in cash, or kind, to gain an improper business advantage.
We encourage raising and donating money for good causes that resonate with our business values. We disclose all charitable donations we make.
We ensure our employees understand charitable contributions are not used to facilitate and conceal acts of bribery.
Dealing with bribery or corruption
Please tell our compliance manager if you feel a bribe or corrupt behaviour is taking place in relation to BlakerTech. This might involve being offered a bribe or being coerced into making a bribe – or if you feel you are a victim of some form of corrupt activity.
Safeguarding and protection
As a result of refusing to accept or offer a bribe, BlakerTech will make sure no one receives adverse treatment due to reporting the concern.
Adverse treatment refers to disciplinary action, dismissal or detrimental treatment in connection to the concern raised.
Our anti-bribery and corruption policy will be clearly communicated to all employees, contractors, suppliers and third parties at the outset of any working relationship.
BlakerTech will record and keep accurate financial documents and have the necessary internal controls and processes in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given, and understand that gifts and acts of hospitality are subject to managerial review.
Our compliance manager monitors and reviews this policy on a regular basis.
This policy does not form part of an employee’s contract of employment and BlakerTech may amend it at any time to improve its effectiveness at dealing with bribery and corruption.
Our internal control processes and procedures have been written to prevent bribery and corruption and are subject to regular reviews and audits to ensure they continue to work effectively.
BlakerTech – Modern Slavery Policy
BlakerTech specialises in advanced recycling solutions and is a sister company to Blaker Ltd., which is one of the longest-established businesses in the Horsham District of West Sussex, South East England.
We are committed to ensuring there is no modern-day slavery or human trafficking in our supply chains or any part of the business.
Our anti-slavery policy statement reflects our commitment to acting ethically and with integrity in our business relationships. We will not support or deal with any business knowingly involved in slavery or human trafficking.
The senior management team shall take responsibility for implementing this policy statement and its objectives and provide adequate resources (training, etc.) to ensure that slavery and human trafficking is not taking place within the organisation or within its supply chains. The company’s anti-slavery policy will be displayed on the company website and on notice boards in the company office.
All new and existing employees are subjected to Right to Work checks to ensure that BlakerTech does not employ illegal workers thereby ensuring compliance with the Immigration, Asylum and Nationality Act 2006. Or 2016?
Employees are required to immediately report any possible breach of the code of conduct to their line manager or a member of the senior management team. This policy applies to all those employed by BlakerTech. The policy will be regularly reviewed by the senior management team to ensure its continuing suitability.
The privacy of visitors is treated with the upmost importance by the company.
The sections below set out information on the types of personal information received and collected when www.blakertech.co.uk is visited and how the company safeguards and protects your personal details and information. BlakerTech will never sell your personal information to third parties.
BlakerTech (the “Company”) respects the privacy concerns of the users of its website, BlakerTech and the services provided therein (the “Site”). The Company provides this privacy statement to explain what information is gathered during a visit to the site and how such information may be used.
This privacy notice provides details of how BlakerTech collects and processes personal data through interactions on its website: www.blakertech.co.uk, including any information visitors may provide through the site when a ‘contact us’ or enquiry form is completed.
BlakerTech has appointed a Data Protection Officer who is in charge of privacy-related matters for us.
Full details are:
Full name of legal entity: BlakerTech Ltd.
Name and title of Data Protection Officer: Robin Plater, Commercial Manager
Telephone: 01403 78363
Unit 1, The Yard,
Anyone who is not happy with any aspect of how BlakerTech collects and uses their data, has the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, BlakerTech would be grateful for prior notification of the complaint so they can try to resolve it in the first instance.
It is very important the information BlakerTech holds is accurate and up to date. Please let them know of any personal information changes by emailing: firstname.lastname@example.org
What data does BlakerTech collect?
Personal data means any information capable of identifying an individual. It does not include anonymised data.
BlakerTech might process certain types of personal data:
- Identity Data which may include first name, maiden name, last name, username, marital status, title, date of birth and gender.
- Contact Data which may include billing address, delivery address, email address and telephone numbers.
- Technical Data which may include internet protocol (IP) addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system, platform and other technology on the devices used to access this website.
- Profile Data whichmay include feedback and survey responses.
- Usage Data which may include information about how visitors use the BlakerTech website, products and services.
- Marketing and Communications Data whichmay include preferences in receiving marketing communications from BlakerTech
BlakerTech might also process Aggregated Data from personal data which does not reveal someone’s identity and as such in itself is not personal data. For example, how BlakerTech reviews usage data to work out the percentage of website visitors using a specific feature of its site. If BlakerTech links the aggregated data with personal data enabling an individual to be identified, it is then treated as personal data.
BlakerTech does not collect any sensitive data. Sensitive data refers to data that includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information and genetic and biometric data. BlakerTech does not collect any information about criminal convictions and offences.
How BlakerTech collects personal data
BlakerTech collects personal date through direct interactions through filling in forms on the BlakerTech website, at trade shows (or other events) or by postal communication, phone, email or otherwise
Examples of instances of personal data collection include:
- subscription to a BlakerTech service or publication
- a marketing or resources request
- when an online purchase is made
- when an account is created
- contact via social media
- contact via customer, service or product reviews
- provision of customer feedback
- via entry to a promotion or survey
Automated technologies or interactions
Third parties or publicly available sources
BlakerTech may receive personal data from various third parties and public sources as set out below:
- Technical data from social media
- Analytics providers such as Google
- Search information providers such as Google
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register
How BlakerTech uses personal data
BlakerTech only uses personal data when legally permitted. The most common uses of personal data are shown below:
- Where BlakerTech needs to perform a contract with a prospect or customer
- Where it is necessary for legitimate interests (or those of a third party) and fundamental rights do not override those interests
- Where BlakerTech must comply with a legal or regulatory obligation
As a rule, BlakerTech does not rely on consent as a legal ground for processing personal data, other than in relation to sending marketing communications via email or text message. You have the right to withdraw consent to marketing at any time by emailing: email@example.com
Reasons for BlakerTech to process personal data
Set out below is why BlakerTech uses personal data and the lawful reasons for which it will process such data.
BlakerTech may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us: firstname.lastname@example.org if you need details about the specific, legal ground we are relying on to process your personal data where more than one ground has been set out below.
Activity: Process and deliver orders including managing payments, fees and charges and collecting any monies owed
Data description: identity, contact, financial, transaction, marketing and communications
Legal grounds for processing: performance of a contract and necessary for BlakerTech to recover debt owed
Activity: register new customer
Data description: identity and contact
Legal grounds for processing: performance of a contract
Activity: to safeguard the BlakerTech site including troubleshooting, testing, system maintenance, back-ups, support, data analysis, hosting, support and reporting
Data description: technical, identity, contact
Legal grounds for processing: ensure the day to day running of BlakerTech, safeguarding network security and provide ongoing administration and IT services.
Data description: identity, contact, profile, marketing and communications.
Legal grounds for processing: performance of a contract, necessary to comply with a legal obligation, required to keep the BlakerTech records updated to understand how customers use its products or services
Activity: where relevant, recommend products or services that might be of benefit or interest
Data description: profile, identity, usage, contact, technical
Legal grounds for processing: legitimately necessary for BlakerTech to grow its business
Activity: utilise data analytics to inform decisions relating to website build, services, marketing and visitor experience.
Data description: usage, technical
Legal grounds for processing: reasonably necessary for audience segmentation and to continually ensure Hill Ash products and services are relevant and meet customer needs.
Online and offline marketing communications for BlakerTech
BlakerTech will only send communications to those who have:
- Specifically requested information from BlakerTech or purchased goods or services; or
- Those who have provided BlakerTech with their details when registering for a promotion or marketing materials; and
- in each case, have not opted out of receiving those communications.
BlakerTech will acquire clear, opt-in consent before sharing personal data with any third party for marketing purposes.
Using clear opt-out links, an instruction to BlakerTech or third parties can be made to stop marketing messages from being sent at any time via email: email@example.com.
Please note: An opt-out from receiving marketing communications does not apply to personal data provided to BlakerTech as a result of a product/service transaction/purchase, warranty registration or product/service experience.
Disclosures of your personal data
BlakerTech might have to share personal data with the following third parties:
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances
- Service providers who provide IT and system administration services
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services
- Third parties who BlakerTech sell, transfer, or merge parts of their business or company assets.
BlakerTech will request all third parties to respect the security of personal data and to treat it in accordance with the law. BlakerTech only allows such third parties to process personal data for specified purposes and in accordance with BlakerTech’s strict instructions.
Legal rights explained
In certain circumstances, users can extend their rights under data protection laws in relation to personal data as follows:
- To request access to personal data
- To request correction of personal data
- To object to processing of personal data
- To request deletion of data
- To restrict the processing of personal data
- To request transfer of personal data
- To exercise the right to withdraw consent
To carry out any of the above rights and actions, please contact: firstname.lastname@example.org
You can visit the following website for further information:
BlakerTech will not levy a charge to access personal data, or for other rights to be exercised. BlakerTech may charge a fee if a request is clearly excessive or unfounded.
BlakerTech may need to request additional information which is specific to confirm an identity and to safeguard the right to access (or to exercise any other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
BlakerTech will try to respond to all legitimate requests within one month. If a request is deemed to require longer than a month to process, in such cases, BlakerTech will notify the individual and keep them appraised of progress.
BlakerTech has implemented appropriate security measures to safeguard personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, BlakerTech restricts access to personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process personal data on the instructions of BlakerTech and they are subject to a duty of confidentiality.
BlakerTech has put in place procedures to deal with any suspected personal data breach and will notify an individual or any applicable regulator of a breach where it is legally required to do so.
Change of purpose
BlakerTech will only use personal data for the purposes for which it was gathered, unless BlakerTech reasonably considers it should be used for another reason and that reason has synergy with the original purpose. To find out more about how the processing for the new purpose is compatible with the original purpose, please email: email@example.com
If BlakerTech needs to use personal data for a purpose unconnected to the original purpose for which it was gathered, BlakerTech will notify the individual and fully explain the legal reasons for processing.
Please note, BlakerTech may process personal data without prior knowledge or consent where this is required or permitted by law.
BlakerTech will only hold personal data for as long as is necessary to fulfil the purposes it was collected for.
By law, BlakerTech has to keep basic information about customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
To determine the appropriate retention period for personal data, BlakerTech considers the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of personal data, the purposes for which BlakerTech processes personal data and whether BlakerTech can achieve those purposes through other means, and the applicable legal requirements.
BlakerTech may anonymise personal data (so that it can no longer be associated with an individual) for research or statistical purposes, in which case, BlakerTech may use this information indefinitely without further notice to the individual.
Third party links
The BlakerTech site includes links to third-party websites, plug-ins and applications. Clicking on the links or enabling connections could allow third parties to collect or share data about a user. In such cases, BlakerTech does not control these third-party websites and is not responsible for their individual privacy statements.
Users can set their browsers to block/refuse browser cookies or to notify if a website sets or access cookies. When cookies are disabled or refused it will impact the visitor experience on the BlakerTech website, e.g. some features might not function properly. For more information please visit: www.blakertech.co.uk
What are cookies?
Cookies are small text files that are stored on your computer or mobile device when you visit a website. They are there to ensure you receive the best experience when you visit a website and are used as a method for websites to store information relating to a specific visitor or website browser when viewing and using the website.
As a user, you can change your cookie settings at any time. However, some of the cookies we use are really essential:
- Strictly necessary: without these cookies our website simply wouldn’t work. To give a few examples, they enable you to log in and out of your account, access secure areas and will recognise if you’ve added an item to your shopping basket, plus much more basic functionality
- Marketing and advertising: third party cookies that record your visit to our website and take note of your browsing patterns. Depending on what products you’ve looked at these cookies will be used to serve up more of what you like relevant to your interests.
- Preference: these cookies remember the information that changes the way our website behaves and looks. One example is the preferred language, another is allowing users to remain logged in after leaving our website.
- Performance and analytical: these third party cookies collect information about how our website is used. The cookies remain anonymous and enhance the user experience.
Further information on cookies
For more information about cookies and how to control their use, please visit the following website: www.allaboutcookies.org.
Please note that if you opt-out of some of the cookies you might not be able to access certain features, services or secure parts of the website.
BlakerTech – Accessibility Policy
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