LWM Solutions Policies

LWM Solutions Limited (“We” and “Our Company”) is committed to protecting and respecting your privacy. This Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read this Policy carefully to understand our practices regarding how we will treat your personal data.

By visiting https://lwmsolutions.co.uk/ (“Website”), you accept and consent to the practices described in this Policy. If you do not accept the terms of this Policy, please refrain from using this Website. This Policy is in direct response the European General Data Protection Regulation 2016/679 (GDPR), the Data Protection Act 2018 and Privacy and Electronic Privacy Regulations (PECR) and any other applicable legislation.

The Policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of the users, this Website and Website owners. Furthermore, the Policy explains how this Website processes, stores and protects user data and information while you browse or use this Website.

Information we may collect and hold about you

We may collect and process information you’ve provided to us, such as your name, email address, mailing address, and contact details.

We may also collect:

• Technical Data: information we collect automatically when you visit our Website or interact with us by email, including the device used to access this Website, its operating system, the connection type and the IP address.
• Social media platforms data: When you engage with us through social media platforms, we will use your social media username (if you interact with us through those channels) to help us respond to your comments, questions or feedback.
• Identity and contact data: Your name and email address are required to respond to any enquiries you make when completing the contact form on our Website.

You may also provide us with information about yourself, such as your name and email address by:

• filling in forms on this Website, such as the “Contact Us” Form;
• contacting us by phone, email or physical mail;
• asking us to contact you in relation to services we provide;
• subscribing to our mailing lists, newsletters or bulletins;
• completing a survey, we send you;
• booking a seminar or event run by us;
• visiting our offices;
• ordering products or services from us;
• requesting downloads of documentation or software;
• requesting support related to software or services;
• interacting with us on social media platforms (such as Linked In or Twitter); or
• reporting a problem with our Website.

Information about your use of our Website is collected by using cookies. You can disable cookies if you wish to do so.

We may also collect personal information when you engage with us on social media platforms, complete any surveys we send to you or enter prize draws or competitions.

We rely on legitimate interest as a basis for processing your personal information when you contact us using the contact form on our Website or when you engage with us through social media channels.

We carry out a balancing test to ensure that our processing is necessary and that your fundamental privacy rights are not outweighed by our legitimate interest in processing that information. Before collecting your data from surveys or prize draws, we will request your consent.

When you visit our Website, we may also collect information about you, including, but not limited to, your IP address, approximate location (town / city level), time of access, the browser you use, your operating system, the pages you visit and what Website you came from.

We may ask you to complete surveys that we use for research purposes.

We may use legal public sources to obtain information about you. We only obtain information from third parties when permitted by law.

Retention of your information

If we are providing services to you, we will retain your personal information for the duration of the services and for six (6) years thereafter, unless otherwise agreed.

When you visit our Website, you will be asked whether you consent to the use of Cookies. If you consent, we will retain the information collected about you in accordance with the retention periods outlined in our Cookies Policy.

How we may use your information

The information we collect from you when visiting our Website is used to analyse your activity on the site so that we can administer, support, improve and develop our business. It is also used for statistical and analytical purposes. Ultimately, this will allow us to optimise the customer experience.

In addition to using your information to fulfil our contract with you, we may also use your information in the following ways (provided that, where we are required to obtain your consent it, you have provided it):

• to monitor our website and improve our products and services;
• to provide you with information about other goods and services we offer that we feel may be of interest to you because they are similar to what you’ve already purchased or asked about;
• to let you know about changes to our services;
• to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to enable us to comply with any legal or regulatory requirements.

Your Rights

Under data protection law, you have rights we need to make you aware of. The rights available to you depend on our reason for processing your information.

1. Right to be informed

The right to information allows individuals (data subjects) to know what personal data is collected about them, why, who is collecting data, for how long, how they can file a complaint, and if there is data sharing involved.

This Policy enables you to duly be informed on all the above.

2. Access to your Data

You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process.

3. Rectification (correction) of your data

You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies.

4. Right to be forgotten

You have the right to ask us to erase your personal information in certain circumstances.

5. Right to restrict processing

You have the right to ask us to restrict the processing of your information in certain circumstances.

6. Right to object processing

You are entitled to officially object to us processing your personal data:

• if the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority;
• for direct marketing purposes (including profiling); and/or
• for the purposes of scientific or historical research and statistics.

We will stop processing your data if you have ground for objecting unless we can show that there are legitimate compelling grounds that override your interests, rights, and freedoms or the processing is for the establishment, exercise or defence of legal claims.

7. Right to data portability

This only applies to the information you have given us. You have the right to ask that we transfer the information you provided us from one organisation to another or give it to you. The right only applies if we are processing data based on your consent or under or in talks about entering into a contract and the processing is automated.

8. Rights in relation to automated decision-making and profiling

This Right is closely connected to the right to object to data processing.

Different types of profiling, such as assessing individual performance at work, economic status, health, personal preferences, interests, reliability, behaviour, or location, are strictly prohibited, especially if it produces a legal effect that significantly affects them.

Processing personal data by automated decision-making is possible only if:

• processing of personal data is allowed by law;
• it is necessary for the execution of the contract;
• individuals gave explicit consent.

However, his Right will not apply if the processing is necessary for the performance of a contract, if it is authorised by the law, or if the processing is based on explicit consent.

9. Right to Opt-Out of the Sale of your data

You have the right, at any time, to direct a business that sells personal information about you to third parties not to sell your personal information.

A business that has received direction not to sell a consumer’s personal information shall be prohibited from selling the consumer’s personal information after its receipt of the consumer’s direction, unless the consumer subsequently provides express authorisation for the sale of the consumer’s personal information.

Any objections relating to the sale or use of personal data for marketing purposes shall be actioned without question or undue delay.

10. Right to Non-discrimination

We shall not discriminate against any person who exercises their rights under the GDPR or any other applicable data privacy legislation.

This includes, but is not limited to:

• denying services;
• charging different rates for services;
• providing different levels or quality of services.

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If you would like to exercise any of your rights in respect of your personal data, please contact us at [email protected] or write to us at 12a Mead Way, Padiham, Burnley, Lancashire, England, BB12 7NG.

You are not required to pay any charge for exercising your rights. We have one month to respond to you.

Changes to this Website Privacy Policy

Any changes we make to this Policy in the future will be posted on this page and, when appropriate, you will be notified by email. Please check back frequently for updates or changes.

About cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

Cookies are used to:

• Measure how you use the website, so the site can be updated and improved based on your needs;
• Remember the notifications you’ve seen, so that we don’t show them to you again;
• You will normally see a notification on our website to remind you that we store a cookie on your file.

Where applicable, this website uses a cookie control system requesting to allow or disallow the use of cookies on their computer / device on their first visit to the website. This complies with the recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer / device.

Cookies on our website

Our website puts small files (known as ‘cookies’) into your computer to collect information about how you use the website and to improve the user experience while visiting the website.

1. We use cookies for the following purposes:

1. authentication and status – we use cookies to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website;
2. personalisation – we use cookies to store information about your preferences and to personalise our website for you;
3. security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
4. analysis – we use cookies to help us to analyse the use and performance of our website and services (these include Google Analytics cookies; Google Analytics gathers information about the use of our website by means of cookies and the information gathered is used to create reports about the use of our website; you can find out more about Google, Inc’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google, Inc’s privacy policy at https://policies.google.com/privacy); and
5. cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

Full details of the cookies that we and our service providers use are as follows:

The cookies in use to deliver Google Analytics results are described in the table below:

2. Security

The security of your personal information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

3. What is the information used for?

The information is sent to ‘Google Analytics’. The information is stored on the Google server in the U.S. The information is collated via google analytics which is then used by the analytical team in the Marketing team to enhance the user experience when you visit our website.

4. Opt-out

In order to provide website visitors with more choices on how data is collected by Google Analytics, Google has developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to stop data being sent to Google Analytics.

The Google Analytics Opt-out Browser Add-on does not affect website usage in any other way. A link to further information on the Google Analytics Opt-out Browser Add-on is provided below for your convenience: https://tools.google.com/dlpage/gaoptout?hl=None

For more information on the usage of cookies by Google Analytics, please refer to the Google website. A link to the privacy advice for this product is provided below for your convenience: https://policies.google.com/privacy

5. Disabling Cookies

If you would like to restrict the use of cookies, you can do so through your Internet browser. Support for the most popular Internet browsers, is provided in the links below for your convenience and will be available for the Internet browser of your choice either online or via the software help (normally available via key F1).

Microsoft Edge

https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09

Google Chrome

https://support.google.com/chrome/bin/answer.py?hl=en-GB&answer=95647&p=cpn_cookies

Mozilla Firefox

https://support.mozilla.org/en-US/kb/block-websites-storing-site-preferences?redirectlocale=en-US&redirectslug=Blocking+cookies

Apple Safari

https://www.apple.com/privacy/manage-your-privacy/

This Code of Ethics outlines the principles and standards of ethical behaviour expected from all employees, contractors, and stakeholders of LWM Solutions Limited. It is designed to guide decision-making and behaviour to maintain the integrity and reputation of the organization. It provides a reference point to make informed decisions based on ethical considerations. This Code also states the consequences of violating a code of conduct policy or ethical misconduct. Establishing clear expectations and promoting ethical behavior, it fosters a positive work environment where respect, honesty, and responsibility are encouraged.

1. Purpose

The purpose of this Code is to:

• Establish clear standards of ethical conduct.
• Promote an environment of honesty, integrity, and respect.
• Ensure compliance with applicable laws and regulations.
• Protect the organisation’s reputation.

2. Scope

This Code applies to all employees, officers, directors, contractors, volunteers, and any other stakeholders representing LWM Solutions Limited.

3. Core Ethical Principles

a. Integrity and Honesty

• Act with honesty and integrity in all professional and business relationships.
• Avoid conflicts of interest and disclose any potential conflicts immediately.

b. Accountability

• Take responsibility for your actions and decisions.
• Report any unethical behaviour or violations of this Code.

c. Respect and Fairness

• Treat everyone with respect and fairness, valuing diversity and inclusion.
• Avoid discrimination, harassment, and any form of abusive behaviour.

d. Compliance with Laws and Regulations

• Adhere to all applicable laws of England and Wales, regulations, and company policies.
• Ensure accurate and truthful reporting of information.

e. Confidentiality

• Protect confidential and proprietary information.
• Do not disclose sensitive information without proper authorization.

f. Professionalism

• Maintain professionalism in all interactions and communications.
• Strive for excellence and continuous improvement in your work.

4. Ethical Decision-Making

When faced with ethical dilemmas, consider the following questions:

• Is it legal?
• Is it fair and honest?
• How would it affect the organization’s reputation?
• Would you feel comfortable if your actions were made public?

5. Reporting Violations

All employees are encouraged to report any violations of this Code of Ethics. Reports can be made to a supervisor, HR department, or through the designated reporting mechanism ([e.g., anonymous hotline or email]).

6. Enforcement & Disciplinary Actions

Violations of this Code of Ethics may result in disciplinary action, up to and including termination of employment. The organization will investigate all reported violations promptly and fairly.

7. Anti-Bribery & Corruption

In accordance with the UK Bribery Act 2010, LWM Solutions Limited, has a zero-tolerance approach to bribery and corruption. Employees must not engage in any form of bribery, whether directly or through a third party.

8. Health, Safety & Environment

Employees must adhere to all health and safety regulations to ensure a safe working environment. The company is committed to environmental sustainability and expects employees to act in an environmentally responsible manner.

9. Data Protection & Privacy

Comply with the UK Data Protection Act 2018 and the General Data Protection Regulation (GDPR). Protect personal data and respect individuals’ privacy.

10. Training & Communication

The organization will provide regular training on the Code of Ethics to ensure all employees understand and adhere to the standards outlined. The Code will be communicated through onboarding sessions, annual training, and available resources.

11. Revision of the Code

This Code of Ethics will be reviewed annually and updated as necessary to ensure it remains relevant and effective.

12. Acknowledgment

All employees of LWM Solutions Limited are required to acknowledge their understanding and commitment to this Code of Ethics.

1. Introduction

1.1  Background to the UK-General Data Protection Regulation (‘UK-GDPR’)

This policy is based on the UK-GDPR and the ICO’s guidance on the UK-GDPR and also complies with the Data Protection Act 2018, which defines the law of processing data on identifiable living people and most of it does not apply to domestic use. Anyone holding personal data for other purposes is legally liable to comply with this Act, with a few notable exceptions.

This policy applies to all personal information processed by, or on behalf of our Company.

All personal data must be handled and dealt with appropriately however it is collected, recorded and used, and whether it is on paper, in electronic records or recorded in other formats, on other media, or by any other means. It includes information held on computers (including email), paper files, photographs, audio recordings and CCTV images.

The purpose of this policy is to help you understand what personal data our Company collects, why we collect it and what we do with it. It will also help you to identify what your rights are and who you can contact for more information, to exercise your rights or to make a complaint.

1.2  Definitions according to Article 4 of the UK-GDPR

Personal data – any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Data controller – the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data;

Data processor – means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

Processing – any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Personal data breach – a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;

Consent of the data subject – means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

Child – the UK-GDPR defines a child as anyone under the age of 13 years old. The processing of personal data of a child shall be lawful only if and to the extent that consent is given or authorised by the holder of parental responsibility over the child.

Third party – a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;

Filing system – means any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis.

Third country– means a country or territory outside the United Kingdom;

2. Data Protection Policy statement

• LWM Solutions Limited, is committed to compliance with all relevant domestic laws in respect of personal data, and the protection of the “rights and freedoms” of individuals whose information we collect and process in accordance with the UK-

• Compliance with the UK-GDPR is described by this policy and other relevant policies such as the

Information Security Policy (ISP) along with connected processes and procedures.

• The UK-GDPR and this policy shall apply to all of our Company’s data processing functions, including those performed on customers’, clients’, employees’, suppliers’, and partners’ personal data, and any other personal data the organisation processes from any

• Our Company has established objectives for data protection and privacy, which are in the Personal Information Management System (PIMS).

• The Data Protection Officer (DPO) shall be responsible for reviewing the register of data processing annually in the light of any changes to the Company activities and to any additional requirements identified by means of Data Protection Impact Assessment (DPIA).

• This policy applies to all Employees/Staff/Contractors/Clients/Partners and third-party providers of our Company. Any breach of the UK-GDPR will be dealt with as described under our Breach Notification Procedure and/or Incident Management Centre (IMC) and may also be a criminal offence, in which case the matter will be reported as soon as possible to the appropriate

• Partners and any third parties working with or for our Company, and who have or may have access to personal data, will be expected to have read, understood and to comply with this policy. No third party may access personal data held by our Company without having first entered into a Data Confidentiality Agreement, which imposes on the third-party obligations no less onerous than those to which our Company is committed, and which gives us the right to audit compliance with the

3.   Personal Information Management System & Information Security Policy (PIMS/ISP)

To support compliance with the UK-GDPR, our Board has approved and supported the development, implementation, maintenance and continual improvement of a documented PIMS, which is integrated within the ISP, for our Company.

All our Employees/Staff and third-party providers identified in the inventory are expected to comply with this policy and with the PIMS/ISP that implements this policy. All Employees/Staff will receive appropriate training.

Scope

The scope of the PIMS will cover all of the PII (Personally Identifiable Information) that the organisation holds including PII that is shared with external organisations such as suppliers, cloud providers, etc.

In determining its scope for compliance with the UK-GDPR, we consider:

• any external and internal issues that are relevant to our purpose and that affect our ability to achieve the intended outcomes of its PIMS/ISP;
• specific needs and expectations of interested parties that are relevant to the implementation of the PIMS/ISP;
• organizational objectives and obligations;
• the organisation’s acceptable level of risk; and
• any applicable statutory, regulatory, or contractual

The PIMS is documented within the ISP system, maintained in our Intranet. Our Company’s objectives for compliance with the UK-GDPR are consistent with this policy, measurable, take into account UK-GDPR privacy requirements and the results from risk assessments and risk treatments, monitored, communicated and updated as appropriate.

4. Responsibilities and roles under the General Data Protection Regulation

• We are a data controller for staff and marketing data and a data processor for client data under the UK-

• The DPO and all those in managerial or supervisory roles throughout our Organisation are responsible for developing and encouraging good information handling practices within our Company.

• The DPO’s role is specified in the UK-GDPR. The DPO is accountable to our Board of Directors for the management of personal data within our Company and for ensuring that compliance with data protection legislation and good practice can be demonstrated. This accountability includes development and implementation of the UK-GDPR as required by this policy, and security and risk management in relation to compliance with the

• The DPO has been appointed to take responsibility for our Company’s compliance with this policy on a day-to-day basis and has direct responsibility for ensuring that our Company complies with the UK-

• The DPO shall have specific responsibilities in respect of procedures such as the Subject Access Request Procedure and is the first point of call for Employees/Staff seeking clarification on any aspect of data protection

• Compliance with data protection legislation is the responsibility of all our Employees/Staff who process personal

• Our Company’s Training Policy sets out specific UK-GDPR training and awareness requirements in relation to specific roles of our Employees/Staff generally.

• Our Employees/Staff are responsible for ensuring that any personal data about them and supplied by them to our Company is accurate and up-to-date.

5. Data Protection principles

All processing of personal data must be conducted in accordance with the data protection principles as set out in Articles 5 and 6 of the UK-GDPR. Our policies and procedures are designed to ensure compliance with the principles.

Personal data must be processed lawfully, fairly and transparently

Lawfully – you must identify a lawful basis before you can process personal data. These are often referred to as the “conditions for processing”, for example, consent.

Fairly – in order for processing to be fair, the data controller has to make sure that personal data are handled in ways that the data subject would reasonably expect and not use it in ways that have unjustified adverse effects on it.

Transparently – Transparent processing is about being clear, open and honest with people from the start about who you are, and how and why you use their personal data. We ensure that we tell individuals about our processing in a way that is easily accessible and easy to understand. You must use clear and plain language.

The specific information that must be provided to the data subject must, as a minimum, include:

• the identity and the contact details of the controller and, if any, of the controller’s representative;
• the contact details of the DPO;
• the purposes of the processing for which the personal data are intended as well as the legal basis for the processing;
• the period for which the personal data will be stored;
• the existence of the rights to request access, rectification, erasure or to object to the processing, and the conditions (or lack of) relating to exercising these rights, such as whether the lawfulness of previous processing will be affected;
• the categories of personal data concerned;
• any further information necessary to guarantee fair

Personal data can only be collected for specific, explicit and legitimate purposes

Personal Data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; The Privacy Procedure sets out the relevant procedures.

Personal data must be adequate, relevant and limited to what is necessary for processing

The DPO is responsible for ensuring that we do not collect information that is not strictly necessary for the purpose for which it is obtained.

All data collection forms (electronic or paper-based), including data collection requirements in new information systems, must include a fair processing statement or a link to privacy statement and approved by the DPO.

The DPO will ensure that, on an annual basis all data collection methods are reviewed by internal audit to ensure that collected data continues to be adequate, relevant and not excessive.

Personal data must be accurate and kept up to date with every effort to erase or rectify without delay

Data that is stored by the data controller must be reviewed and updated as necessary. No data should be kept unless it is reasonable to assume that it is accurate. The DPO is responsible for ensuring that all staff are trained in the importance of collecting accurate data and maintaining it.

Employees/Staff/clients/contractors and third-party providers should be required to notify the Company of any changes in circumstance to enable personal records to be updated accordingly. It is the responsibility of the Company to ensure that any notification regarding change of circumstances is recorded and acted upon.

The DPO is responsible for ensuring that appropriate procedures and policies are in place to keep personal data accurate and up to date, taking into account the volume of data collected, the speed with which it might change and any other relevant factors.

On at least an annual basis, the DPO will review the retention dates of all the personal data processed by our Company, by reference to the data inventory, and will identify any data that is no longer required in the context of the registered purpose. This data will be securely deleted/destroyed in line with the Information Disposal Policy.

The DPO is responsible for responding to requests for rectification from data subjects within one month. This can be extended to a further two months for complex requests. If our Company decides not to comply with the request, the DPO must respond to the data subject to explain its reasoning and inform them of their right to complain to the supervisory authority and seek judicial remedy.

Personal data must be kept in a form such that the data subject can be identified only as long as is necessary for processing.

Where personal data is retained beyond the processing date, it will be minimised/ encrypted/ pseudonymised in order to protect the identity of the data subject in the event of a data breach. Personal data will be retained in line with the ISP and, once its retention date is passed, it must be securely destroyed as set out in this procedure.

The DPO must specifically approve any data retention that exceeds the retention periods defined in the ISP and must ensure that the justification is clearly identified and in line with the requirements of the data protection legislation. This approval must be written.

Personal data must be processed in a manner that ensures the appropriate security

 The DPO will carry out a Data Protection Risk Assessment (DPIA) taking into account all the circumstances of our Company’s controlling or processing operations.

In determining appropriateness, the DPO should also consider the extent of possible damage or loss that might be caused to individuals (e.g., staff or customers) if a security breach occurs, the effect of any security breach on the Company itself, and any likely reputational damage including the possible loss of customer trust.

When assessing appropriate technical measures, the DPO shall consider the following:

• Password Protection
• Automatic locking of idle terminals;
• Removal of access rights for USB and other memory media;
• Virus checking software and firewalls;
• Role-based access rights including those assigned to temporary staff;
• Encryption of devices that leave the organisations premises such as laptops;
• Security of local and wide area networks;
• Privacy enhancing technologies such as pseudonymisation and anonymisation;
• Identifying appropriate international security standards relevant to the Company’s procedures.

When assessing appropriate organisational measures, the DPO shall consider the following:

• The appropriate training levels throughout our Company;
• Measures that consider the reliability of employees (such as references etc.);
• The inclusion of data protection clause in employment contracts;
• Identification of disciplinary action measures for data breaches;
• Monitoring of staff for compliance with relevant security standards;
• Physical access controls to electronic and paper-based records;
• Adoption of a clear desk policy;
• Storing of paper-based data in lockable fire-proof cabinets;
• Restricting the use of portable electronic devices outside of the workplace;
• Restricting the use of employees’ own personal devices being used in the workplace;
• Adopting clear rules about passwords;
• Making regular backups of personal data and storing the media off-site.

These controls have been selected on the basis of identified risks to personal data, and the potential for damage or distress to individuals whose data is being processed. Our Company’s compliance with this principle is contained in its PIMS, which has been developed in line with the ISP.

The controller must be able to demonstrate compliance with the UK-GDPR’s other principles (accountability)

The UK-GDPR includes provisions that promote accountability and governance. These complement the UK-GDPR’s transparency requirements. The accountability principle in Article 5(2) requires you to demonstrate that you comply with the principles and states explicitly that this is your responsibility.

Our Company will demonstrate compliance with the data protection principles by implementing data protection policies, adhering to codes of conduct, implementing technical and organisational measures, as well as adopting techniques such as data protection by design, DPIAs, breach notification procedures and incident response plans.

6. Personal Data individuals’ rights

Each individual shall have the following rights regarding data processing, and the data that is recorded about them: 

• To make access requests regarding the nature of information held and to whom it has been disclosed.
• To prevent processing likely to cause damage or distress.
• To prevent processing for purposes of direct marketing.
• To be informed about the mechanics of automated decision-taking process that will significantly affect them.
• To not have significant decisions that will affect them taken solely by automated process.
• To sue for compensation if they suffer damage by any contravention of the UK-GDPR.
• To take action to rectify, block, erase or destroy inaccurate data.
• To request the supervisory authority to assess whether any provision of the UK-GDPR has been contravened.
• To have personal data provided to them in a structured, commonly used and machine-readable format, and the right to have that data transmitted to another controller.
• To object to any automated profiling that is occurring without

Our Company ensures that individuals may exercise these rights by making data access requests as described in the Acceptable Use Agreement, which shall include the Subject Access Request Procedure. This procedure also describes how our Company will ensure that its response to the data access request complies with the requirements of the UK-GDPR. 

Individuals shall also have the right to complain to the Company related to the processing of their personal data, handling of a request from a data subject and appeals from a data subject on how complaints have been handled in line with the Complaints Procedure.

7. Consent

• Our Company understands “consent” to mean that it has been explicitly and freely given, and a specific, informed and unambiguous indication of the data subject’s wishes that, by statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her. The data subject can withdraw their consent at any
• Our Company understands “consent” to mean that the data subject has been fully informed of the intended processing and has signified their agreement, while in a fit state of mind to do so and without pressure being exerted upon them. Consent obtained under duress or on the basis of misleading information will not be a valid basis for
• There must be some active communication between the parties to demonstrate active consent. Consent cannot be inferred from non-response to a communication. The Controller must be able to demonstrate that consent was obtained for the processing
• For sensitive data, explicit written consent of individuals must be obtained unless an alternative legitimate basis for processing
• In most instances, consent to process personal and sensitive data is obtained routinely by the Company using standard consent documents e.g., when a new client signs a contract, or during induction for participants on
• Where our Company provides online services to children, parental or custodial authorisation must be obtained. This requirement applies to children under the age of 13. Our Company does not routinely process data in this 

8. Security of Data

• All Employees/Staff are responsible for ensuring that any personal data that our Company holds and for which they are responsible, is kept securely and is not under any conditions disclosed to any third party unless that third party has been specifically authorised by our Company to receive that information and has entered into a confidentiality
• All personal data should be accessible only to those who need to use it, and access may only be granted in line with the Access Control Policy.
• Care must be taken to ensure that PC screens and terminals are not visible except to authorised Employees/Staff of the Company. All Employees/Staff are required to enter into an Acceptable Use Agreement before they are given access to organisational information of any sort, which details rules on screen time-outs.
• Manual records may not be left where they can be accessed by unauthorised personnel and may not be removed from business premises without explicit written authorisation. As soon as manual records are no longer required for day-to-day client support, they must be removed from secure archiving in line with the Information Disposal Policy.
• Personal data may only be deleted or disposed of in line with the Information Retention procedure. Manual records that have reached their retention date are to be shredded and disposed of as “confidential waste”. Hard drives of redundant PCs are to be removed and immediately destroyed as required by the Information Disposal Policy.

9. Disclosure of Data

The Company must ensure that personal data is not disclosed to unauthorised third parties which includes family members, friends, government bodies, and in certain circumstances, the Police. All Employees/Staff should exercise caution when asked to disclose personal data held on another individual to a third party. It is important to bear in mind whether or not disclosure of the information is relevant to, and necessary for the conduct of our Company’s business.

10.   Retention and Disposal of Data

• The Company shall not keep personal data in a form that permits identification of data subjects for longer a period than it is necessary, in relation to the purpose(s) for which the data was originally

• The Company may store data for longer periods if the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, subject to the implementation of appropriate technical and organisational measures to safeguard the rights and freedoms of the data

• The retention period for each category of personal data will be set out in the Information Retention procedure along with the criteria used to determine this period including any statutory obligations the Company has to retain the

• The Company’s information retention and information disposal procedures apply in all

• Personal data must be disposed of securely in accordance with the sixth principle of the UK-GDPR. Any disposal of data will be done in accordance with the secure disposal

11.   Data Transfers 

On 28 June 2021 the EU Commission adopted decisions on the UK’s adequacy under the EU’s General Data Protection Regulation (EU GDPR) and Law Enforcement Directive (LED). In both cases, the European Commission has found the UK to be adequate. This means that most data can continue to flow from the EU and the EEA without the need for additional safeguards.

All exports of data from the UK and the European Economic Area (EEA) to non-European Economic Area countries (referred to in the UK-GDPR as “third countries”) are unlawful unless there is an appropriate “level of protection for the fundamental rights of the data subjects”. 

The broader area of the EEA is granted “adequacy” on the basis that all such countries are signatories to the GDPR. The non-EU EEA member countries (Liechtenstein, Norway and Iceland) apply EU regulations through a Joint Committee Decision.

Binding corporate rules

The Company may adopt approved binding corporate rules for the transfer of data outside the EU. This requires submission to the relevant supervisory authority for approval of the rules that the Company is seeking to rely upon. 

Model contract clauses

The Company may adopt approved model contract clauses for the transfer of data outside of the UK and the EEA. If the Company adopts the model contract clauses approved by the relevant supervisory authority there is an automatic recognition of adequacy.

Exceptions

In the absence of an adequacy decision, Privacy Shield membership, binding corporate rules and/or model contract clauses, a transfer of personal data to a third country or international organisation shall only take place on one of the following conditions:

• the individual has explicitly consented to the proposed transfer, after having been informed of the possible risks of such transfers for the data subject due to the absence of an adequacy decision and appropriate safeguards;
• the transfer is necessary for the performance of a contract between the individual and the controller or the implementation of pre-contractual measures taken at the data subject’s request;
• the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the data subject between the controller and another natural or legal person;
• the transfer is necessary for important reasons of public interest;
• the transfer is necessary for the establishment, exercise or defence of legal claims; and/or
• the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving

12.   Data Inventory

The Company has established a Data Inventory and Data Flow process as part of its approach to address risks and opportunities throughout its UK-GDPR compliance project. The Company’s Data Inventory and Data Flow determines:

• business processes that use personal data;
• source of personal data;
• volume of data subjects;
• description of each item of personal data;
• processing activity;
• maintains the inventory of data categories of personal data processed;
• documents the purpose(s) for which each category of personal data is used;
• recipients, and potential recipients, of the personal data;
• the role of the Company throughout the data flow;
• key systems and repositories;
• any data transfers; and
• all retention and disposal

Our Company is aware of any risks associated with the processing of particular types of personal data:

• The Company assesses the level of risk to individuals associated with the processing of their personal data. Data Protection Impact Assessments (DPIAs) are carried out in relation to the processing of personal data by the Company, and in relation to processing undertaken by other organisations on behalf of the Company.
• The Company shall manage any risks identified by the risk assessment in order to reduce the likelihood of a non-conformance with this
• Where a type of processing, in particular using new technologies and taking into account the nature, scope, context and purposes of the processing is likely to result in a high risk to the rights and freedoms of natural persons, our Company shall, prior to the processing, carry out a DPIA of the impact of the envisaged processing operations on the protection of personal data. A single DPIA may address a set of similar processing operations that present similar high risks.
• Where, as a result of a DPIA it is clear that the Company is about to commence processing of personal data that could cause damage the Company and/or distress to the data subjects, the decision as to whether or not the Company may proceed must be escalated for review to the
• The DPO shall, if there are significant concerns, either as to the potential damage or distress, or the quantity of data concerned, escalate the matter to the supervisory
• Appropriate controls will be selected, as appropriate and applied to reduce the level of risk associated with processing individual data to an acceptable level, by reference to the Company’s documented risk acceptance criteria and the requirements of the UK-GDPR.

1. Purpose

The purpose of this policy is to detail procedures for the retention and disposal of information and personal data. This policy refers to both hard and soft copy documents, unless specifically stated otherwise.

2. Scope

This policy covers all data collected by and stored on the Company owned or leased systems and media, regardless of location. It applies to both data collected and held electronically (including photographs, video and audio recordings) and data that is collected and held as hard copy or paper files. The need to retain certain information may be mandated by federal or local law, federal regulations and legitimate business purposes, as well as the EU General Data Protection Regulation (GDPR).

3. Reasons for Data Retention

The Company retains only that data that is necessary to effectively conduct its program activities, fulfil its mission and comply with applicable laws and regulations. Reasons for data retention include:

1. Providing an ongoing service to the data subject (e.g. sending a newsletter, publication or ongoing program update to an individual, ongoing training or participation in the Company’s programs, processing of employee payroll and other benefits).
2. Compliance with applicable laws and regulations associated with financial and programmatic reporting by the Company to its funding agencies and other donors.
3. Compliance with applicable labour, tax and immigration laws.
4. Other regulatory requirements.
5. Security incident or other investigation.
6. Intellectual property preservation.
7. Litigation.

4. Review

Each department processing personal data must go through its ‘closed records’ at least every 6 months to determine whether the records should be destroyed, retained for a further period or transferred to an archive for permanent preservation.

5. Retention period for paper records

1. Records should only be kept for as long as they are needed to meet the operational needs of the business, and to fulfil legal and regulatory requirements.

1. If any (or more) below applies then you must determine the length the records should be kept for, otherwise the records must be destroyed in line with this policy.

6. Destruction of records

No destruction of a record should take place without assurance that:

• The record is no longer required by any part of the business;

• No work is outstanding by any part of the business;

• No litigation or investigation is current or pending which affects the record;

• There are no current to pending Subject Access Requests which affect the record.

Records should be destroyed in the following ways:

7. Audit trail

1. There is no requirement to document the disposal of records which have been listed on the records retention schedule.

1. If records are disposed of earlier or kept for longer than listed on the records retention schedule, then they must be recorded for audit purposes.

1. This will provide an audit trail for any inspections conducted by the Information Commissioner Office and will aid in addressing Subject Access Request, where we no longer hold the material.

WHERE TO GO FOR ADVICE AND QUESTIONS

Questions, comments, complaints and requests regarding this policy are welcomed and should be addressed to our office address, 12a Mead Way, Padiham, Burnley, Lancashire, England, BB12 7NG or to our Data Protection Officer at [email protected].

In addition, please do not hesitate to contact us if you suspect any privacy or security breaches.

OTHER RELEVANT POLICIES

This policy supplements and should be read in conjunction with our other policies and procedures in force from time to time, including without limitation our:

• Data Protection Policy;
• Privacy Policy;
• IT and Communications Systems Policy and any other IT, security and data related policies, which are available on the Portal; and
• Code of Professional & Ethical Conduct.

1. What is the purpose of this document?

LWM Solutions Limited is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with data protection law, including the General Data Protection Regulation (“UK-GDPR”). It applies to all employees, workers and contractors. LWM Solutions Limited is a (“Data Controller“). This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice. This notice applies to current and former employees, and candidates for new positions. This notice does not form part of any contract of employment or other contract to provide services. This notice can be updated at any time and we will inform you if this occurs. It is important that you read this notice, together with any other privacy notice that is provided on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

2. Data protection principles.

We will comply with Data Protection Law. This says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.

3. The kind of information we hold about you. 

• Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
• There are “Special Categories” of more sensitive personal data which require a higher level of protection.
• We collect, store, and use the following categories of personal information about you:
• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
• Dates of birth, marriage and divorce.
• Gender.
• Marital status and dependants.
• Next of kin, emergency contact and death benefit nominee(s) information.
• National Insurance number.
• Bank account details, payroll records and tax status information.
• Salary, annual leave, pension and benefits information.
• Start date, leaving date.
• Copy of driving licence, passport, birth and marriage certificates.
• Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).
• Full employment records.
• Compensation history.
• Performance and appraisal information.
• Disciplinary and grievance information.
• Secondary employment and volunteering information
• Other information obtained through electronic means such as swipe card records.
• Information about your use of our information and communications systems.
• Accident book, first aid records, injury at work and third-party accident information.
• Passport details, nationality details and information about convictions/allegations of criminal behaviour.
• Evidence of your right to work in the UK/immigration status.

4. How is your personal information collected?

We typically collect personal information about employees, workers and contractors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We will sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies.   

5. How we will use information about you. 

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

• Where it is necessary for performing the contract, we have entered into with you.
• Where we need to comply with a legal obligation.
• Where it is in the public interest to do so.

There can be rare occasions where it becomes necessary to use your personal information to protect your interests (or someone else’s interests).

Situations in which we will use your personal information

We need all the categories of information in the list above (see: The kind of information we hold about you) to enable us to perform our role as employer; to enable us to comply with legal obligations, or where it is necessary to do so in the public interest.

The situations in which we will process your personal information are listed below:

• Making a decision about your recruitment or appointment.
• Determining the terms on which you work for us.
• Checking you are legally entitled to work in the UK and to provide you with the security clearance appropriate for your role.
• Paying you and, if you are an employee, deducting tax and National Insurance contributions.
• General administration of the contract we have entered into with you.
• Conducting performance reviews, managing performance and determining performance requirements.
• Making decisions about salary reviews and compensation.
• Assessing qualifications for a particular job or task, including decisions about promotions.
• Gathering evidence and any other steps relating to possible grievance or disciplinary matters.
• Making decisions about your continued employment or engagement.
• Making arrangements for the termination of our working relationship.
• Education, training and development requirements.
• Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.
• Ascertaining your fitness to work, managing sickness absence.
• Complying with health and safety obligations.
• To prevent fraud.
• To monitor your business and personal use of our information and communication systems to ensure compliance with our IT policies.
• To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
• To conduct data analytics studies to review and better understand employee retention and attrition rates.
• Equal opportunities monitoring.
• Dealing with Freedom of Information Act/Environmental Information Regulations requests

Some of the purposes will overlap and there can be several grounds which justify our use of your personal information.

If you fail to provide personal information

If you fail to provide certain information when requested, we will not be able to fully perform the contract we have entered with you (such as paying you or providing a benefit), or we could be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

 Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated or new purpose, we will notify you and we will explain the legal basis which allows us to do so. 

Please note that we will, if necessary, process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. How we use particularly sensitive personal information

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We will, if necessary, process special categories of personal information in the following circumstances:

• Where we need to carry out our legal obligations or exercise our employment-related legal rights and in line with our data protection policy.

• Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.

• In some circumstances, we will process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Our obligations as an employer

We will use your particularly sensitive personal information in the following ways:

• We will use information relating to leave of absence; this can include sickness absence or family related leave, to comply with employment and other laws.
• We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations, or for one of the other reasons outlined above in section: ‘How we use particularly personal information’. In limited circumstances, if the need arises, we will approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us. 

7. Information about criminal convictions

We will only use information relating to criminal convictions or alleged criminal behaviour where the law allows us to do so.

We will only collect information about criminal convictions or allegations of criminal behaviour where it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions/allegations as part of the recruitment process.

We are allowed to use your personal information in this way where it is in line with our data protection policy and where we need to carry out our legal obligations or exercise our employment-related legal rights.

8. Data retention

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

In some circumstances we will anonymise your personal information so that it can no longer be associated with you, in which case we will use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with applicable laws and regulations. 

9. Rights of access, correction, erasure, and restriction

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “Data Subject Access Request“). Request correction of the personal information that we hold about you.
• Request erasure of your personal information. Object to processing of your personal information where we are relying on a legitimate interest and where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information.
• Request the transfer of your personal information to another party.

10. Right to withdraw consent

In the limited circumstances where you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us via email, once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

11. Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We will also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact us via email.

This Policy is to establish guidelines and procedures for managing information risks within our Company

PURPOSE

Information that is collected, analysed, stored, communicated and reported upon might be subject to theft, misuse, loss and/or corruption.

However, the implementation of controls to protect information must be based on an assessment of the risk posed to the Company, and must balance the likelihood of negative business impact against the resources required to implement the mitigating controls, and any unintended negative implications of the controls.

This Policy sets out the principles that the Company uses to identify, assess and manage information risk, in order to support the achievement of its planned objectives, and aligns with the overall Company risk management framework and approach.

It aims to protect the confidentiality, integrity, and availability of Company’s information assets and ensure compliance with relevant laws and regulations.

This high-level Information Risk Management Policy sits alongside the Information Security Policy and Data Protection Policy to provide the high-level outline of and justification for the Company’s risk-based information security controls.

OBJECTIVES

The Company’s information risk management objectives are focused on:

1. information risks being identified, managed and treated according to a fixed risk tolerance;
2. the Information Asset Owner’s consent for physical, procedural and technical controls;
3. physical, procedural and technical controls are balanced with Employee/User experience and security;
4. physical, procedural and technical controls are cost-effective and proportionate.

SCOPE

The Information Risk Management Policy and its supporting controls, processes and procedures apply to all information used at the Company, in all formats. This includes information processed by other organisations in their dealings with the Company.

The Information Risk Management Policy and its supporting controls, processes and procedures apply to all individuals who have access to Company’s information, technologies and apps, including external parties that provide information processing services to the Company.

ROLES & RESPONSIBILITIES

Clear roles and responsibilities are defined for managing information risks. This includes designating an Information Security Officer responsible for overseeing the implementation and enforcement of this Policy.

The Information Security Officer:

1. is responsible for managing the risk assessment process;
2. maintains an up-to-date risk register;
3. conducts risk assessments after which action for medium and low risks are recommended;
4. is responsible for assessing and reviewing high risks;
5. has visibility of the risk register; and
6. must also take an active role in identifying and reporting new risks.

COMPLIANCE & REVIEW

This Policy is reviewed and updated to ensure compliance with applicable laws, regulations and industry standards by the Information Security Officer on an annual basis or more frequently if required.

POLICY STATEMENT

Information risk assessment is a formal and repeatable method for identifying the risks facing an information asset. It is used to determine their impact, and identify and apply controls that are appropriate and justified by the risks.

It is the Company’s policy to ensure that information is protected from a loss of:

1. Confidentiality: information will be lawfully accessible only to authorised individuals.
2. Integrity: the accuracy and completeness of information will be maintained.
3. Availability: information will be accessible to authorised Employees/Users and processed only as required by law or lawful purpose.

INFORMATION CLASSIFICATION

All information assets are classified based on their sensitivity and criticality. This classification determines the level of protection required and the access controls to be implemented. 

ACCESS CONTROL

Access to information assets is granted based on the principle of least privilege. Only authorised individuals are given access, and access rights is regularly reviewed and revoked when no longer required.

INCIDENT RESPONSE

An incident response plan is developed and maintained to address security incidents promptly and effectively. This plan includes procedures for reporting, investigating, and mitigating incidents, as well as communication and notification requirements.

TRAINING & AWARENESS

Regular training and awareness programs conducted to train Employees/Users on information risk management best practices, including the proper handling and protection of information assets.

RISK ASSESSMENT

Risk assessments must be completed with access to and an understanding of:

1. the Company’s business processes;
2. the impact to the Company of risks to business assets;
3. the technical systems in place supporting the business;
4. the legislation to which the Company is subject;
5. up-to-date threat and vulnerability assessments.

A risk assessment exercise should be completed:

1. for every new information-processing system;
2. following modification to systems or processes which could change the threats or vulnerabilities;
3. following the introduction of a new information asset;
4. following changes to the threat environment or detection of new vulnerabilities. 

THREATS & VULNERABILITIES

The Company considers all potential threats and vulnerabilities applicable to a particular system, whether natural or human, accidental or malicious.

Threat and vulnerability information are obtained from specialist security consultancies, local and national law enforcement agencies and security services, and contacts across the sector and region.

It is the responsibility of the Information Security Officer to maintain channels of communication with appropriate specialist organisations. 

RISK REGISTER

The calculations listed in the risk assessment process form the basis of a risk register.

All risks are assigned an owner and a review date.

The risk register is held in the Information Security document store, with access controlled by the Information Security Officer. 

RISK TREATMENT

The risk register includes a risk treatment decision. The action must fall into at least one of the following categories:

1. Pending: where a potential risk has been identified but needs initial investigation.
2. Tolerate the risk: where the risk is already below the Company’s risk appetite and further treatment is not proportionate.
3. Treat the risk: where the risk is above the Company’s risk appetite but treatment is proportionate; or where the treatment is so simple and cost effective that it is proportionate to treat the risk even though it falls below the Company’s risk appetite.
4. Transfer the risk: where the risk cannot be brought below the Company’s risk appetite with proportionate treatment but a cost-effective option is available to transfer the risk to a third party.
5. Terminate the risk: where the risk cannot be brought below the Company’s risk appetite with proportionate effort/resource and no cost-effective transfer is available.

The Information Security Officer in collaboration with the Information Asset Owner reviews medium and low risks, and recommend suitable action.

RISK APPETITE & TOLERANCE

The Company has agreed a series of risk appetite statements.

While not exhaustive, these give a good overview of the Company’s desire to pursue or tolerate risk in pursuit of its business objectives.

The risk appetite statements give the Information Security Officer a framework within which to conduct risk assessments and make recommendations for appropriate treatments.

PURPOSE

This high-level Information Security Policy sits alongside the “Information Risk Management Policy” and “Data Protection Policy”. This Policy provides a high-level outline of, and justification for, the Company’s risk-based information security controls. 

LEGAL BASIS

Information that is collected, analysed, stored, communicated and reported upon may be subject to theft, misuse, loss and corruption.

Information may be put at risk by reduced awareness and/or training, and the breach of security controls.

Information security incidents can give rise to embarrassment, financial loss, non-compliance with standards and legislation, as well as possible judgements being made against the Company. 

OBJECTIVES

Our Company’s security objectives are key to improving Employees/Users awareness and knowledge of security best practices.

We focus on:

• information risks being identified, managed and treated according to a fixed risk tolerance;
• authorised Employees/Users’ access and share information securely in order to perform their duties and roles;
• physical, procedural and technical controls are balanced with Employee/User experience and security;
• contractual and legal obligations relating to information security being met at all times;
• all business and administrative activities always consider information security matters;
• individuals accessing information are aware of their information security responsibilities;
• incidents affecting information assets are quickly and effectively resolved and work as a motive to improve our security controls.

SCOPE

The Information Security Policy and its supporting controls, processes and procedures apply to all information used and processed by the Company, in all formats. This includes information processed by other organisations in their dealings with the Company.

The Information Security Policy and its supporting controls, processes and procedures apply to all individuals who have access to the Company’s information, technologies and apps, including external parties that provide information processing services to the Company. 

COMPLIANCE MONITORING

Compliance with the controls in this Policy shall be monitored by the Information Security Team, and reported to the Information Security Officer.

REVIEW

A review of this Policy is undertaken by the Company’s Legal Team on an annual basis or more frequently if required.

POLICY STATEMENT

It is the Company’s policy to ensure that information is protected from a loss of:

1. Confidentiality: information will be lawfully accessible only to authorised individuals.
2. Integrity: the accuracy and completeness of information will be maintained.
3. Availability: information will be accessible to authorised Employees/Users and processed only as required by law or lawful purpose.

The Company will implement an Information Security Management System based on certified standards as required by law. The Company shall be mindful of the approaches adopted by its stakeholders, including third partners.

The Company adopts a risk-based approach to the application of the following controls:

1. Information Security Policies

A set of lower-level controls, processes and procedures for information security are defined, in support of the high-level Information Security Policy and its stated objectives. This suite of supporting documentation as approved by the Company, shall be published and communicated to Company’s Employees/Users and relevant external parties. 

2. Organisation of Information Security

The Company defines and implements suitable governance arrangements for the management of information security. This includes identification and allocation of security responsibilities, to initiate and control the implementation and operation of information security within the Company.

The Company has appointed Information Security Officer and take accountability for information risk.

3. Human Resources Security

The Company’s security policies and expectations for acceptable use will be communicated to all Employees/Users to ensure that they understand their information security obligations and responsibilities. Information security training will be made available to all Employees/Users. Poor or inappropriate behaviour will be addressed.

Where practical, security responsibilities will be included in role descriptions, person specifications and personal development plans.

4. Information Assets management

All information assets will be documented and accounted for.

This includes:

1. Information: any information that can be used to identify a person, including sensitive information;
2. Software;
3. Electronic information processing equipment;
4. Service benefits;
5. Human Resources.

Owners will be identified for all information assets and will be responsible for the maintenance and protection of their assets.

All information assets are classified according to their legal requirements, business value, criticality and sensitivity. Classification indicates appropriate handling requirements. All information assets will have a defined retention and disposal schedule.

5. Access Control

Access to all information will be controlled and will be driven by business requirements. Access will be granted or arrangements made for Employees/Users according to their role and the classification of information, only to a level that will allow them to carry out their duties.

A formal user registration and de-registration procedure will be maintained for access to all information systems and services. This will include mandatory authentication methods based on the sensitivity of the information being accessed, and will include consideration of multiple factors as appropriate.

Specific controls will be implemented for users with elevated privileges, to reduce the risk of negligent or deliberate system misuse. The separation of duties will be implemented, where practical.

6. Cryptography

The Company will provide guidance and tools to ensure proper and effective use of cryptography to protect the confidentiality, authenticity and integrity of information and systems.

7. Physical & Environmental Security

Information Processing Facilities (IPF) are housed in secure areas (sites where sensitive information is handled or housed) physically protected from unauthorised access, damage and interference by defined security perimeters. Layered internal and external security controls are in place to deter or prevent unauthorised access and protect assets. This includes those that are critical or sensitive, against forcible or hidden attacks. 

8. Operations Security

The Company ensures the correct and secure operations of information processing systems.

This includes:

1. documented operating procedures;
2. use of formal change and capacity management;
3. controls against malware;
4. defined use of logging;
5. vulnerability management.

9. Communications Security

The Company maintains network security controls to ensure the protection of information within its networks. The Company also provides the tools and guidance to ensure the secure transfer of information both within its networks as well as with external entities. This is done line with the classification and handling requirements associated with each particular type/category of information. 

10. System Acquisition, Development & Maintenance

Information security requirements are defined during the development of business requirements for new information systems or changes to existing information systems.

Controls to reduce any risks identified are implemented where appropriate.

Systems development are always subject to change control and separation of test, development and operational environments.

11. Supplier Relationships

The Company’s information security requirements will be considered when establishing relationships with suppliers, to ensure that assets accessible to suppliers are protected.

Suppliers’ activity is monitored and audited according to the value of the assets and the associated risks.

12. Information Security Incident Management

Guidance will be available on what constitutes an information security incident and how this should be reported. Actual or suspected breaches of information security must be reported and shall be investigated. The appropriate action to correct the breach will be taken, and any learning built into controls.

13. Information Security Aspects of Business Continuity Management

The Company has implemented arrangements to protect critical business processes from the effects of major failures of information systems or disasters. This is to ensure their timely recovery in line with documented business needs. This will include appropriate backup routines and built-in resilience.

Business continuity must be maintained and tested in support of this policy.

Business impact analysis is undertaken, detailing the consequences of:

1. disasters;
2. security failure(s);
3. loss of service;
4. lack of service availability. 

14. Third-Party Management

Third-party vendors, suppliers and/or contractors shall be required to adhere to the same information security standards as the Company and this Policy. Contracts with third parties shall include provisions for data protection and security audits.

15. Compliance

The design, operation, use and management of information systems must comply with all statutory, regulatory and contractual security requirements.

Currently this includes:

1. data protection legislation;
2. the payment card industry standard (PCI-DSS);
3. the government’s Prevent strategy;
4. the Company’s contractual commitments;
5. the Company’s Policies and Procedures.

The Company uses a combination of internal and external audits to demonstrate compliance against chosen standards and best practice, including against internal policies and procedures.

This include:

• IT health checks;
• Gap analyses against documented standards;
• Internal checks on staff compliance;
• Returns from Information Asset Owners.

Introduction

This HMRC COMPLIANCE POLICY (hereinafter the “Policy”) outlines the commitment of LWM Solutions Limited (hereinafter the “Company” and/or “we”, “our”, “us”) to adhere to all relevant laws and regulations set forth by His Majesty’s Revenue and Customs (HMRC). It is designed to ensure that our company conducts its tax affairs accurately, transparently, and in full compliance with the law. 

Scope

This Policy applies to all employees, directors, and officers of the Company, including temporary staff, contractors, and consultants. It covers all aspects of our tax obligations, including but not limited to corporate tax, VAT, PAYE, and National Insurance contributions.

Commitment to Compliance

The Company is committed to maintaining the highest standards of tax compliance. We recognize that complying with HMRC regulations is essential to our reputation, financial integrity, and legal standing. We strive to meet all our tax obligations in a timely and accurate manner.

Roles & Responsibilities

The Board of Directors holds ultimate responsibility for ensuring compliance with HMRC regulations. The Finance Director is responsible for overseeing the implementation of this Policy and ensuring that all tax-related activities are conducted in accordance with HMRC guidelines. All employees are expected to comply with this Policy and report any concerns or potential violations to the Finance Director.

Tax Planning and Reporting

The Company is aligned with our business operations and complies with HMRC regulations. We will not engage in aggressive tax planning or artificial arrangements designed to evade tax liabilities. All tax returns and reports are prepared accurately and submitted on time. We maintain proper our records and documentation to support all tax filings.

Training & Awareness 

We also provide regular training to relevant employees to ensure they are aware of HMRC requirements and understand their responsibilities under this Policy. Training sessions cover updates to tax laws, reporting obligations, and procedures for identifying and managing tax risks.

Internal Controls & Audits

The Company implements and maintains effective internal controls to ensure tax compliance. These controls include regular reviews and audits of our tax processes and records. Any discrepancies or issues identified during audits shall be addressed promptly, and corrective actions will be implemented as necessary.

Engagement with HMRC

We maintain open and transparent communication with HMRC. Any queries or requests for information from HMRC shall be responded to promptly and accurately. In the event of any errors or issues in our tax filings, we disclose these to HMRC and take appropriate steps to rectify them.

Risk Management

The Company adopts a proactive approach to managing tax risks. This includes identifying potential tax risks through regular assessments and implementing measures to mitigate these risks. We stay informed about changes in tax laws and regulations and adjust our policies and procedures accordingly.

Whistleblowing & Reporting Concerns

Employees are encouraged to report any concerns or suspicions of non-compliance with this Policy. Reports can be made anonymously and will be treated confidentially. No employee will face retaliation for reporting genuine concerns. Any reports of non-compliance will be investigated thoroughly, and appropriate actions will be taken.

Review & Monitoring

This Policy shall be reviewed annually by the Finance Director to ensure its effectiveness and alignment with current HMRC regulations. Any changes to the Policy will be approved by the Board of Directors and communicated to all employees. 

Conclusion

The Company is dedicated to maintaining compliance with HMRC regulations. By adhering to this Policy, we aim to uphold our ethical standards, protect our reputation, and contribute positively to the UK Tax System. All employees are expected to support and adhere to this Policy to ensure our continued compliance and success.

This Policy covers rules to be followed with respect to:

• Anti-discrimination of employee for hiring and promoting;
• Consequences if not followed;
• Reporting Mechanism; or
• Investigation & Resolution Mechanism.

LWM Solutions Limited, recognise that everyone has a contribution to make to our society and a right to equal opportunity.

No job applicant or employee, member, volunteer or organisation/individual to which we provide services will be discriminated against by us on the grounds of:

• age;
• colour;
• gender (including sex, marriage, gender re-assignment);
• race (including ethnic origin, colour, nationality and national origin);
• disability;
• national origin;
• sexual orientation;
• religion or belief; or
• veteran status.

I. Objective

LWM Solutions Limited has endeavoured to capture the spirit of the Equal Opportunity Act 2010.

Equal Opportunity Act 2010 replaced all previous anti-discrimination laws, including the Anti-Discrimination Act (1977), with a single Act, making the law easier to understand and strengthening protection in some situations.

LWM Solutions Limited is committed to promoting equal employment opportunities and a workplace that is free of all forms of discrimination. Equal opportunity means that all staff experience fairness, impartiality and equal access to all career initiatives in the LWM Solutions Limited.

LWM Solutions Limited commitment to equal opportunity promotes an inclusive work environment that values and accepts the diverse cultural and social backgrounds of its staff.

LWM Solutions Limited will take affirmative action to ensure that this Policy is implemented, with particular regard to: advertising, application procedures, compensation, demotion, employment, fringe benefits, job assignment, job classification, layoff, leave, promotion, recruitment, rehire, social activities, training, termination, transfer, upgrade, and working conditions.

II. Scope and Applicability

Applicable to HR and all the employees as well.

III. Aim & Commitment

This Policy aims to make workplace free from discrimination, sexual harassment and victimisation.

We Aim

To promote equal opportunities, eliminate discrimination and harassment through the following:

• Opposing all forms of unlawful and unfair discrimination.
• All employees (whether part-time, full-time or temporary), associates, independent contractors and beneficiaries shall be treated fairly and with respect.
• All employment opportunity announcements/vacancies will be advertised internally and externally simultaneously and will include a statement on equal opportunities to make it understood that the foregoing is Company Policy and all employment decisions are based on individual merit only. Selection for employment, promotion, training or any other benefit will be based on aptitude and ability. LWM Solutions Limited will continue by the employment entities with which it deals, that the foregoing is a mandatory Company Policy. All selection/rejection decisions will be recorded.
• All employees (whether part-time, full-time or temporary), associates, independent contractors and beneficiaries shall be assisted and encouraged to develop their full potential and the talents and resources of individuals will be fully utilised to maximise the efficiency of the organisation.
• It is the Company’s Policy to ensure and maintain a working environment free of coercion, harassment, and intimidation at all job sites, and in all facilities at which employees are assigned to work. All employees (whether part-time, full-time or temporary), associates, independent contractors and beneficiaries have a legal and moral obligation not to discriminate and to immediately report any violation of the policy or any incidents of discrimination against any individual or group of individuals to their supervision.
• It is our Company’s Policy that all company activities, facilities, and job sites are non-segregated. Separate or single-user toilet and changing facilities are provided to assure privacy. 

We Commit:

• To create an environment in which individual differences and the contributions of all our staff, volunteers, members and beneficiaries are recognised and valued.
• Every employee, volunteer, member and beneficiary are entitled to be part of an environment that promotes dignity and respect for all. No form of intimidation, bullying or harassment will be tolerated.
• Training, development and progression opportunities are available to all staff members.
• Equality is good management practice and makes sound sense. Breaches of our equality Policy will be regarded as misconduct and could lead to disciplinary proceedings or employee formal warning or termination of employment or cooperation.
• This Policy is fully supported by the management committee and has been agreed upon by all its members and the employee representatives.
• The Policy will be monitored and reviewed annually.

The successful implementation of this Policy depends on the awareness and commitment of all staff members and associates. Hence, all new staff members and associates will be made aware of its existence and on joining the organisation, and reminded they must conform with it on a regular basis.

IV. Policy/Process

Policy Objective

The objectives of this Equal Employment Opportunity (EEO) and Anti-Discrimination Policy are to ensure that all:

• LWM Solutions Limited’s employees or potential employees do not suffer unfair discrimination in the workplace.
• Individuals and groups within the LWM Solutions Limited work in an environment where all decisions are free of discrimination, where they have equal opportunity based on relevant abilities, skills and merit.
• Employees are encouraged to take positive action towards promoting equal opportunity throughout the organization.
• Personnel actions such as compensation, benefits, transfers, layoffs, company-sponsored training programs and social and recreational programs will be administered on a non-discriminatory basis.
• Application of labour laws to be uniformly applied in the organization.

EEO & Provisions of Services

It refers to the principle which ensures that all employees and potential employees of LWM Solutions Limited are treated equitably and fairly regardless of their race, sex or disability.

Everyone has an equal chance when applying for jobs, transfers, promotions, training opportunities and in their working conditions.

The following activities shall be conducted in a uniform manner:

• Recruitment procedure and selection criteria for appointment or engagement of a person as an employee;
• Promotion and transfer of an employee;
• Training and staff development for an employee; and
• Terms of employment or any other employee-related activity

What is Workspace Discrimination

Discrimination occurs when someone is treated unfavourably because of a certain attribute. Discrimination may involve some or all of the following:

• Conduct that can be considered harassing, coercive or disruptive, including sexual harassment.
• Making offensive ‘jokes’ about another worker’s clan, ethnic background, colour, sex, appearance or disability.
• Expressing negative stereotypes about particular groups, e.g., “married women shouldn’t be working”.
• Judging someone on their political or religious beliefs rather than their work performance.
• Using selection processes based on irrelevant attributes such as ethnic or clan group, age, sex or disability rather than on knowledge, skills and merit.

Parameters of Discrimination – Strictly Prohibited

LWM Solutions Limited and its employees shall strive to create a workplace that is free from discrimination in their employment practices against any potential or existing employees, and shall not discriminate on a person’s:

• Age or other circumstances
• Colour
• Cultural or social beliefs such as religious
• Educational background
• Race, ethnicity or nationality
• Spiritual, traditional or customary beliefs
• Political opinion
• Physical features or physical disabilities
• Gender identity and expression
• Marital status
• Pregnancy or judging the impacts of potential pregnancy on decisions
• Breastfeeding
• Sexual orientation
• Health or physical disability or impairment
• Medical record
• HIV status
• Family responsibilities
• Trade union membership
• Reserve disciplinary forces, e.g., police

Modern Slavery Statement

LWM Solutions Limited has a zero-tolerance approach to any form of modern slavery and human trafficking. These behaviours and acts are strictly prohibited and we are committed to acting ethically, with integrity and transparency in all business dealings and to implementing effective systems and controls in place to safeguard against any form of modern slavery taking place within our business or our supply chain.

We expect all those in our supply chain to comply with our values fully. We use the following key performance indicators to measure how effective we have been in ensuring that slavery and human trafficking are not taking place in any part of our business or supply chains.

V. Complaint Process & Procedures

A person wishing to make a complaint of discrimination can consult and file a complaint with the EEO & Anti-Discrimination (AD) Committee. The complaint should be made in writing and addressed to chairperson of the committee within five (5) working days of any such incident of discrimination.

The constitution of the Committee shall be:

• Chair of the “EEO & Anti-Discrimination” Committee
• Internal Officers – 2 Members from Middle-Level Management [One Female & One Male]
• HR Department Head

Process to Be Followed

Once a complaint has been filed with the EEO & AD Committee:

(a) Investigation

Once a complaint has been filed, an investigation will be undertaken immediately. In instances where there is an alleged respondent, the respondent will be notified immediately. The complainant and the respondent will both be interviewed along with any individuals who may be able to provide relevant information.

Where the alleged discrimination is an organizational practice or procedure, that practice or procedure will be investigated immediately. Where the investigation finds systemic discrimination within the organization, that practice or procedure will be changed promptly.

(b) Mediation

LWM Solutions Limited supports resolving matters through mediation provided that it is consistent with organizational duties, obligations and needs. Mediation can only be undertaken voluntarily. If both parties agree to participate, matters may be resolved through mediation in the following circumstances. Once the matter has been investigated and LWM Solutions Limited has determined the facts of the case, LWM Solutions Limited may use mediation to develop appropriate solutions to the complaint; and, in rare instances, where the incident is an isolated event and the parties do not dispute the facts, LWM Solutions Limited will act diligently to ensure that matters are dealt with in a manner that ensures the safety and protection of everyone within the organization.

(c) Timelines

LWM Solutions Limited will investigate all complaints immediately and will work towards the prompt resolution and prevention of discriminatory acts and practices. The first round of investigation and conclusion shall be arrived at within ten (10) working days from the date of filing of the complaint.

(d) Fairness

All complaints will be investigated in the same manner with the aim of promoting, fairness and equality.

(e) Confidentiality & the Right to Privacy

LWM Solutions Limited will preserve the confidentiality of all individuals involved in a discrimination complaint. The preservation of confidentiality may be affected by the employer’s duty to prevent discrimination in/at LWM Solutions Limited and by the alleged respondent’s right to know the nature of the complaint being made against them and who has made it so that they can respond.

If the investigation fails to find evidence to support the complaint, no documentation concerning the complaint will be placed on the file of the respondent. LWM Solutions Limited will retain all documentation for twelve (12) months for informational purposes in the event that there is an internal appeal or a complaint filed with an outside agency.

(f) Outcomes & Remedies

LWM Solutions Limited will act swiftly to ensure that the discriminatory practice is stopped as soon as possible and may remedy the situation in a number of ways. Where the investigation determines that discrimination has occurred or the matter has been successfully mediated, outcomes may include moving the respondent to another department, changing the respondent’s job duties, or a letter of apology. Actions taken to remedy a discriminatory situation should not have a negative effect on the complainant. The main concerns of the employer will be to ensure that the discrimination ends and to restore workplace harmony.

(g) Appeal Process

Within ten (10) days from the result of the first round of investigation, either the complainant or the respondent may make a written request that an investigation be reviewed stating which aspect of the investigation is inadequate. The request must be submitted to CEO of LWM Solutions Limited, who will determine if the investigation is to be re-opened in order to address the concerns raised.

In case the appeal is taken up, then the investigation shall be completed within fifteen (15) working days by the same committee with the inclusion of an independent member. The result of the appeal shall be binding on the complainant, respondent and all related parties concerned for all purposes.

VI. Special Circumstance and Exception

No exception to this Policy is allowed. Any Deviation from this Policy has to be approved by HR. Any changes to this Policy need to be approved by Legal and Compliance.

VII. Non-compliance and Consequence

Any instances of discrimination or favouritism with proper evidence that comes to or is brought to the notice of the management will be dealt with strictly in accordance with the terms of this Policy and any other appropriate policies of the Company.

LWM Solutions Limited (the “Company”) seeks to provide a work environment that is safe and enjoyable for all. Bullying and harassment is a behaviour that makes someone feel intimidated or offended. Harassment is unlawful under the Equality Act 2010.

Workplace bullying and harassing behaviours have a detrimental effect on the Company and its people. Due to these behaviours is created an unsafe working environment, result in a loss of trained and talented staff, cause the breakdown of teams and individual relationships, increase absenteeism and reduce efficiency and productivity.

Examples of bullying or harassing behaviour include, but are not limited to:

• spreading malicious rumours
• unfair treatment
• picking on or regularly undermining someone
• denying someone’s training or promotion opportunities

The unwanted behaviour is related, indicative and not exhaustive, to one of the following:

• age
• sex
• disability
• gender reassignment
• marriage and civil partnership
• pregnancy and maternity
• race
• religion or belief
• sexual orientation

Bullying and harassment can happen:

• face-to-face
• by letter
• by email
• by phone

This Policy applies to behaviours that occur:

• In connection with work, even if it occurs outside normal working hours;
• During work activities, for example, when dealing with clients;
• At work related events and functions, for example, at Christmas parties; and
• On social media platforms where staff members interact.

The Company recognises that workplace bullying may involve comments and behaviours that offend some people and not others. The Company accepts that individuals may react differently to certain comments and behaviour. That is why a minimum standard of behaviour is required of all staff members. This standard aims to be respectful of all staff. This Policy applies to all staff members including employees, contractors, associates, trainees and volunteers.

What employees should do if they’re bullied or harassed

Employees should see if they can sort out the problem informally first. If they cannot, they should talk to:

• Their Manager/Supervisor;
• The Human Resources (HR) Department;
• The Trade Union representative (if applicable).

Complaints of bullying, harassment and workplace violence will be taken seriously and will be handled immediately. If any of the employees make a complaint of workplace bullying, harassment or violence it will be taken seriously and will be dealt with sympathetically and in a confidential manner (except where the Company deems it is necessary to disclose information in order to properly deal with the complaint). Staff members will not be victimised or treated unfairly for making a complaint.

Managers’ and supervisors’ roles

Managers and supervisors should also ensure that all staff members understand this Policy and consequences of non-compliance. When managers and supervisors observe harassment, bullying or workplace violence occurring, they should take steps to prevent this conduct from continuing and warn the person or people involved of the consequences if the behaviour continues (including disciplinary measures up to and including termination of employment).

Staff’s Role

The Company expects staff members:

• Not to engage in harassment, bullying or workplace violence;
• Not to aid, abet or encourage others to engage in harassment, bullying or workplace violence; To behave in a responsible and professional manner;
• Treat others in the workplace with courtesy and respect;
• Listen and respond appropriately to the views and concerns of others; and
• To be fair and honest in their dealings with others.

Other Measures

The Company also recognises the need for open communication in the workplace. The Company may implement what training it considers necessary in relation to behavioural standards and where appropriate will hold meetings to address standards, expectations and any issues. The frequency, dates and form of this training and meetings will be determined by management of the Company.

MORE INFORMATION

If you need any more information about workplace bullying, harassment, or violence please contact your Manager/Supervisor and/or the HR Department.

Money Laundering and Terrorist Financing have been identified as major threats LWM Solutions Limited and, indeed, the international financial services community. The United Kingdom, along with many other countries, has passed legislation to prevent money laundering and combat terrorism.

Legal and Regulatory Framework

The principal requirements, obligations and penalties on which our company’s financial crime systems and controls are based derive from:

• The proceeds of Crime Act 2002 (POCA), as amended by the:
• Serious Organized Crime and Police Act 2005 (SOCPA); and the
• Proceeds of Crime Act (amendment) Regulations 2007;
• The Terrorism Act 2000, as amended by the:
• The Anti-Terrorism, Crime & Security Act 2001; and the
• Terrorism Act (amendment) Regulations 2007;
• The Terrorism Act 2006;
• The Bribery Act 2010;
• The Money Laundering Regulations 2007, transposing the requirements of the E.U.’s third money laundering directive;
• The FCA handbook of rules and guidance, and in particular, the senior management arrangements, systems and controls (SFFISC) sourcebook, which relates to the management and control of money laundering risk; and
• The Joint Money Laundering Steering Group (JMLSG) guidance for the UK financial sector prevents money laundering / combating terrorist financing.

Our Company’s Policies & Principles

LWM Solutions Limited is responsible for the following policies covering:

• Anti-Money Laundering ⁄ Counter-Terrorist Financing ⁄ Counter-Proliferation Financing;
• Training;
• Anti-Bribery & Anti-Corruption; and
• Introducers.

These policies and principles are designed to ensure that all group companies comply with the legal and regulatory requirements in the UK and with their local obligations.

Anti-Money Laundering (AML) Policy

Our company’s AML policy is designed to ensure compliance with the requirements and obligations set out in UK legislation, regulations, rules and industry guidance for the financial services sector, including the need to have adequate systems and controls in place to mitigate risks in firms that are used to facilitate financial crime. The AML policy sets out the minimum standards, which all our companies must comply with and includes:

• Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KFFIC) procedures, including enhanced due diligence for those customers presenting higher risk, such as politically exposed persons (peps) and correspondent banking relationships;
• Establishing and maintaining risk-based systems and procedures to monitor ongoing customer activity;
• Developing procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
• Maintaining appropriate records for the minimum prescribed periods;
• Training and awareness for all relevant employees; and
• Providing appropriate management information and reporting to senior management of the group’s compliance with the requirements.

Training

All employees receive training on the Anti-Money Laundering and Counter-Terrorist Financing policies and principles at least once a year, with more detailed and advanced training for those whose roles involve major financial risks. Failure to comply with these policies and principles may give rise to disciplinary action, up to and including dismissal.

Anti-Bribery & Anti-Corruption Policy

We have a zero-tolerance policy toward bribery and corruption. Our company recognises that bribery and corruption adversely affect communities wherever they occur. They can threaten laws, democratic processes and fundamental human freedoms while distorting free trade and competition. Corruption is often associated with organised crime, money laundering and, on occasion, the financing of terrorism. In addition, the level and efficacy of investment and financing can be reduced, particularly within economically disadvantaged societies.

We are committed to applying high standards of honesty and integrity consistently across our global operations and in all our business dealings. Fie is subject to the provisions of the UK bribery act 2010 and the US foreign corrupt practices act, which have an extra-territorial effect globally, as well as applicable local anti-bribery laws in relevant jurisdictions.

Introducers

In addition to the anti-bribery and anti-corruption policy, our company has an introducer clause described in the Introducer agreement. The clause covers the activities of all third parties that generate or retain business or secure a business benefit for us. These third parties are termed “introducers” by LWM Solutions Limited(hereinafter our/the “Company”). Potential examples would include senior advisors, lead generators, and existing clients of our Company. Our introducer policy protects our Company against bribery and corruption risks, reputational risk, and broader operational and conduct risks associated with introducers. Our employees must apply the specific controls and procedures set out in the policy.

LWM Solutions Limited Governance & Conformance

Regular reviews of the effectiveness of these group policies are carried out in addition to audits periodically undertaken by our Company’s internal audit function. This provides senior executive management oversight committees and the board audit committee with the necessary assurance regarding the operating effectiveness of the group’s controls relating to these policies.