This is the Data Protection and Privacy policy of Trace Isys Limited (“Trace”) and covers the services offered by Trace at www.traceisys.com (“the Website(s)”).

The purpose of this statement is to inform users of the Trace Website what information is collected about them when they visit this site, how this information is used, if it is disclosed and the ways in which we protect users' privacy.

By visiting this Website, you are accepting and consenting to the practices described in this privacy policy which may be amended from time to time. If you use this Website you are agreeing to be bound by this policy at any time.

Passwords


There are no logons nor passwords issued in order to use the Website.

Confidentiality and Security


When you register with Trace, we may ask for information such as your name, email address, address and contact details in order to send you newsletters to which you subscribe and for the provision of information about products or services you have requested.

Any information you provide will be held securely and in accordance with the Data Protection Act 1998.

There are a limited number of circumstances where we may share some or all data about you that we hold with others, such as:

In the event that our business assets are ever sold to or purchased by another company;
If we are under a duty to disclose or share personal data about you in order to comply with any legal obligation at the request of public authorities; or
On your express consent.

By submitting data, you agree to this collection, transfer, storing or processing of data about you for the purposes described in this policy. We will take all reasonable steps to ensure data about you is treated securely in accordance with this policy, and all information you provide to us is stored on our secure servers or those of our sub-contractors. However, the personal information that we collect from you may be sent and stored outside the European Economic Area ("EEA"). By registering on the website or sending us your personal information by other means, you are indicating your consent for your personal information to be sent, stored and processed outside the EEA.

If at any time you want to be removed from our subscriber’s list, please notify us by email at: privacy.isys@tracegroup.com

Using cookies

Cookies are small data files that websites generate and ask to store on your computer. Most websites use cookies in one form or another. They are typically used to:

remember settings, so you don’t have to keep re-entering them whenever you visit a new page
remember information you give to a website, such as a list of products in your shopping basket
measure how you use the website so we can make sure it meets your needs

To learn more about cookies and how to manage them, visit www.AboutCookies.org, or please read on to find out more about how we use cookies.

Measuring Website Usage 


Google Analytics is in use to collect information about how visitors use this site. This provides us with important information that can enable the site to work better. We do not link this information to your name or address.

This Anti-Slavery and General Employment policy applies to the Trace Group and all its associated companies and has been adopted as policy by each company’s board at a duly convened board meeting.

We do not use forced labour.  We shall set working hours, wages and overtime pay in compliance with UK laws.  Employees shall be paid at least the National Living wage.  We shall only employ staff who meet the applicable minimum working age requirement

We have a suite of policies and procedures to ensure that we treat all employees with dignity and respect, regardless of gender, race, religion, ethnicity, age, sexual orientation, national origin, disability or any other protested characteristic.  Specialist training on human rights is available for relevant employees.  Employees are employed solely on their ability to perform in their personal role.

All employees work in the London offices of the Trace Group with no outsourcing or off-shoring for any business functions.

Trace Isys evaluate our supply chain annually, reviewing the size, location and nature of the business of each supplier.  Higher risk suppliers are contacted to ensure they are complying with the Modern Slavery Act 2015.

A training program is being implemented to raise awareness of modern slavery issues and to ensure that slavery, forced labour and human trafficking do not take place anywhere in our business or supply chains.

Our Compliance and Data Protection Officer is responsible for implementing, managing and monitoring our compliance to the Modern Slavery Act 2015 and reports directly to the Board of Trace Isys.

The Company is committed to the prevention of bribery by those employed and associated with it and is committed to carrying out business fairly, honestly and openly, with zero-tolerance towards bribery.

The Company expressly prohibits employees from offering, promising, giving, or requesting, agreeing to receive or receiving any financial or other advantage to another person or business with the intention of gaining an improper financial or other advantage.

All employees have a responsibility to prevent, detect and report all instances of bribery.  If employees are offered any gift or hospitality, they should not accept it without approval from the Company.  Employees should never offer a gift or hospitality to a customer, supplier or other person with the intention of gaining a business advantage. Any business gifts or invitations to hospitality events that are issued must always be agreed in advance.

Acts of bribery and/or corruption will always be taken seriously and have severe consequences for the employee and the Company. Employees have a duty to disclose any concerns about bribery (or any other unlawful activity) whether in relation to other staff members, contractors or themselves. Employees should report their concerns in confidence to the Company as soon as practicable.

If an employee is found to have accepted or given any bribe, this may result in disciplinary action up to and including dismissal. This may also lead to criminal investigation and a potential prison sentence and fine for those found guilty of bribery in addition to potential fines on the Company.

Introduction

Integrity and transparency are of the highest importance to us and so we aim to conduct our business to the highest legal and ethical standards. We are aware of the laws in place relating to tax evasion, including the Criminal Finances Act 2017, and take our responsibilities seriously. The failure to prevent the facilitation of tax evasion undertaken by representatives of the group renders the group liable to criminal sanctions including an unlimited fine.

This policy applies to anyone who works on our behalf or provides services to any company in the group including employees, directors, workers including agency workers, volunteers, contractors, consultants and any other party with whom we do business.

What is Tax Evasion?

Tax evasion is the practice of using illegal methods to avoid paying tax. It involves deliberate and dishonest conduct and is not the same as tax avoidance (which is or may be legal). It frequently involves contrived, artificial transactions that serve no purpose other than to reduce tax liabilities.

Indicators of tax evasion are (and the following is a non-exhaustive list):

• requests for payment by cash;
• overly-complex payment mechanisms;
• transactions involving overly complex supply chains;
• transactions involving private banking facilities;
• incomplete or non-standard invoices or other records relating to the payment of tax;
• making false statements in relation to the payment of tax or failure to register with relevant bodies tasked with ensuring tax compliance;
• failure to register for VAT;
• any individual or supplier asking to be paid gross when they should be paid net

Our stance on the facilitation on tax evasion

Tax evasion and facilitating the evasion of tax are criminal offences. Both acts, besides being illegal, will damage our reputation and the confidence of our customers, suppliers and business partners.

We will not be party to tax evasion or the facilitation of tax evasion of any form. We take a zero-tolerance approach to the facilitation of tax evasion. We are committed to:

• rejecting the facilitation of tax evasion; and
• not recommending the services of others who do not have reasonable prevention procedures in place

Staff Responsibilities 

It is strictly prohibited for any employee or person working on our behalf or in connection with us to take part in any activity, directly or indirectly, relating to tax evasion or its facilitation.

Staff must not:

• undertake any action which facilitates tax evasion
• aid or abet any action of tax evasion

Staff are required to report any behaviour which reasonably leads them to believe that tax evasion or the facilitation of tax evasion is occurring in any way which is connected to the group.

If we have reason to believe that staff have breached any obligation placed upon them by this policy, action will be taken which is appropriate to our relationship with them. This includes the instigation of a disciplinary procedure which could result in summary dismissal by virtue of gross misconduct, or the termination of our business arrangement.

Reporting Concerns

Staff must notify their manager at the earliest stage if they suspect that tax evasion or the facilitation of tax evasion may be occurring. The failure to report a suspicion, of itself, may constitute an offence of facilitation of tax evasion and therefore we strongly encourage the reporting of all and any concerns.

Any concerns should be reported to the Group Finance Director. An investigation will then be carried out and the member of staff may need to give an account of their suspicions including names, dates and any other pertinent information.

Staff may also report a concern using the group’s Whistleblowing policy which is available in the Staff Handbook.

Detriment

No individual who reports a concern relating to tax evasion under this policy, or the Whistleblowing policy, will be subject to detriment because of their actions.

Additionally, no individual will be subject to detriment because they have refused to take part in any behaviour which is prohibited by this policy.

The group reserves the right to make amendments to this policy at any time without notice.