www.fin1-compliance.com 
E: [email protected] T: 0207 1998383

FIN1 

THE CONSULTANCY OF CORPORATE GOVERNANCE AND COMPLIANCE (CCGC) LTD

Governance, Policies, and Privacy   

FIN1 (CCGC) LTD  has adopted The Corporate Governance Guide and Principles for Unlisted Companies in Europe, An Initiave of ecoDA

The document can be accessed at: http://ecoda.org/uploads/media/GUIDANCE_-_2010_CG_for_Unlisted_-_EU.pdf  


FIN1 (CCGC) LTD is proud to be: 
  • Member of London Chamber of Commerce and Industry (LCCI)
  • Member of the British Standards Institution
  • Member of the Italian Chamber of Commerce and Industry for the UK 


FIN1 (CCGC) LTD has in place the following policies: 

  • Anti-Money Laundering (AML) Policy 
  • Anti-Bribery Policy
  • Whistleblowing Policy
  • Corporate Social Responsibility (CSR) Statement 
  • Ethical Policy 
  • Hospitality and Gifts Policy 
  • Expenses Policy  


If you have any questions about the policies we have in place, please request a duly authorised member of your staff to contact us at: ei@fin1-compliance.com 


Ethical Policy 


1. Purpose
FIN1 THE CONSULTANCY OF CORPORATE GOVERNANCE AND COMPLIANCE (CCGC) LTD with Company number: 09869037 (“the Company” and/or “FIN1 (CCGC) LTD”) is committed to the practice of responsible corporate behaviour.

Through its business practices the Company seeks to protect and promote the human rights and basic freedoms of all its employees and agents.

Further the Company is committed to protecting the rights of all of those whose work contributes to the success of the Company, including those employees and agents of suppliers to the Company.

The Company is also committed to eliminating bribery and corruption. It is essential that all employees and persons associated with the Company adhere to this policy and abstain from giving or receiving bribes of any form.

This policy is non-exhaustive, and all aspects of the Company’s business should be considered in the spirit of this policy.

2. Human Rights

The Company is vehemently opposed to the use of slavery in all forms; cruel, inhuman or degrading punishments; and any attempt to control or reduce freedom of thought, conscience and religion.

The Company will ensure that all of its employees, agents and contractors are entitled to their human rights as set out in the Universal Declaration of Human Rights and the Human Rights Act 1998.

The Company will not enter into any business arrangement with any person, company or organisation which fails to uphold the human rights of its workers or who breach the human rights of those affected by the organisation’s activities.

3. Workers’ Rights

The Company is committed to complying with all relevant employment legislation and regulations. The Company regards such regulations and legislation as the minimum rather than the recommended standard.

No worker should be discriminated against on the basis of age, gender, race, sexual orientation, religion or beliefs, gender reassignment, marital status or pregnancy. All workers should be treated equally. Workers with the same experience and qualifications should receive equal pay for equal work.

No worker should be prevented from joining or forming a staff association or trade union, nor should any worker suffer any detriment as a result of joining, or failing to join, any such organisation.

Workers should be aware of the terms and conditions of their employment or engagement from the outset. In particular workers must be made aware of the wage that they receive, when and how it is to be paid, the hours that they must work and any legal limit which exists for their protection and any overtime provisions. Workers should also be allowed such annual leave, sick leave, maternity / paternity leave and such other leave as is granted by legislation as a minimum.

The Company does not accept any corporal punishment, harassment in any form, or bullying in any form.

4. Environmental Issues

The Company is committed to keeping the environmental impact of its activities to a minimum and has established an Environmental Policy in order help achieve this aim.

As an absolute minimum, the Company will ensure that it meets all applicable environmental laws in whichever jurisdiction it may be operating.

5. Conflicts of Interest

The Company holds as fundamental to its success the trust and confidence of those with whom it deals, including clients, suppliers and employees. Conflicts of interest potentially undermine the relationship of the Company with its partners.

In order to help preserve and strengthen these relationships the Company has developed a Corporate Hospitality and Gifts Policy, which provide rules and guidelines concerning the conduct of its officers and employees aimed at minimising the possibility of conflicts of interest and at avoiding risks associated with bribery and corruption.

All officers, employees and representatives of the Company are expected to act honestly and within the law.

6. Information and Confidentiality

Information received by employees, contractors or agents of the Company will not be used for any personal gain, nor will it be used for any purpose beyond that for which it was given.

The Company will at all times ensure that it complies with all applicable requirements of data protection legislation (including, but not limited to, the Data Protection Act 1998) in force from time to time.

7. Shareholders and Investors

The Company, its officers, employees and representatives, and its subsidiaries are committed to ensuring that no act or omission which is within their power and which would have the effect of deliberately, negligently or recklessly misleading the shareholders, creditors or other investors in the Company occurs.

8. Suppliers and Partners

8.1  The Company expects all suppliers and partners to work towards and uphold similar ethical and moral standards.

8.2 The Company will investigate the ethical record of potential new suppliers before entering into any agreement. Further, the Company reserves the right to request information from suppliers regarding the production and sources of goods supplied.

8.3 The Company reserves the right to withdraw from any agreement or other arrangement with any supplier or partner who is found to have acted in contravention of the spirit or principles of this Ethical Policy.

9. Bribery and Corruption

9.1 The Company is fundamentally opposed to any acts of bribery and to the making of facilitation payments as defined by the Bribery Act 2010.

9.2 Employees and any other persons associated with the Company such as agents, subsidiaries and business partners are not permitted to either offer or receive any type of bribe and/or facilitation payment.

9.3 All employees are encouraged to report any suspicion of corruption or bribery within the Company in accordance with the Whistleblowing Policy.

9.4 Should any employee or associated person be in doubt when receiving or issuing gifts and hospitality, he/she must refer to the Gift and Hospitality Policy.

9.5 The Company uses its reasonable endeavours to implement the guidance principles on bribery management that are published, from time to time, by Secretary of State in accordance with Section 9 of the Bribery Act 2010.

9.6 If an employee or associated person is found guilty of giving or receiving a bribe, he/she will be personally criminally liable and may be subject to disciplinary action.

9.7 Anyone found guilty of bribery, will be responsible for bearing any related remedial costs such as losses, court fees or expenses.

10. Service Provision and Business Conduct   

10.1 We conduct our business by bringing into effective action the highest levels of integrity, due diligence, and professionalism.
10.2 We are fully committed to the protection of the financial system and continuously strive to contribute towards the implementation of a sound financial crime prevention policy in accordance with UK, EU and International Standards.

10.3 We have a strict policy in place for not offering our opinion, services, and professional training to entities and individuals involved or suspected of being involved in arrangements to handle criminal and/or terrorist financing proceeds.
10.4 We dedicate a substantial part of our time to follow and stay aligned with national and international regulatory compliance developments.
10.5 We are committed to the invaluable principles of client confidentiality and data protection. In the interests of discharging our statutory duties and obligations, we cooperate with national and international regulatory authorities with a view to promote and enhance public policy, institutional safety and soundness and foster a culture of good compliance.
10.6 We are committed 100% to fiscal transparency and to promoting and enhancing tax justice throughout conducting our business.
10.7 We have a zero tolerance policy towards all forms of financial crime, money laundering, terrorism and terrorism financing, bribery and corruption, tax evasion, cybercrime, trade misinvoicing, non-conformity with HM Treasury and the Department for Business, Innovation & Skills, and fraud of any form and type whatsoever. 
10.8 We conduct our business by implementing preventive and ongoing KYB/KYC/CDD/Third Party Risk Management controls.
10.9 Whilst doing business, we are fully committed to rejecting and reporting any form of anti-social behaviour or any suspicious behaviour that may potentially compromise the application of financial regulation, public safety and the rule of law.
10.10 The Directors of FIN1 adhere fully to the set of duties laid down in the Department for Business Innovation & Skills | Directors’ duties, BIS Director (10/15) Version 1.0 www.gov.uk/BIS 

Customer Treatment Policy

At FIN1 we believe that our customers are our most valuable asset. We strive to work closely with our clients and encourage them to refer or recommend us to their sister companies, trusted business partners and established contacts. 
One of our main strategic goals is to see progressive development and repetition of the range of services we offer. 
We are also highly specialised in carrying out private research and executive training, and when circumstances necessitate, we will work at anti-social hours to successfully deliver our projects. 
Yet we are not more expensive than other competitors simply because we know:
The rates of our most expensive competitors.
We clearly demonstrate from the outset to our clients the savings and benefits of hiring us.
We have done identical work before.
We have the special skills in place.
We work with precision, concision, confidentiality, and operational discipline.
We have an impeccable track record.

Discount Policy
We offer selective discounts as part of our strategy to attract new clients and to generate additional business in the form of introductory discounts or special discounts that are triggered once a client reaches a set level of service purchases. 
We also offer attractive monthly retainer packages for our clients.  
Our discounts policy conforms to the principle of proportionality - i.e. treating our customers and our competitors fairly in the interests of promoting and enhancing fair competition and sustainability. 

Cookies Policy

How to Manage Cookies


Cookies allow you to take advantage of some of our website's essential features; we recommend you leave them turned on. Please be aware that if you disable or delete cookies our website will not work. The Help menu on the menu bar of most browsers will tell you how to enable or prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can also disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on's settings or visiting the website of its manufacturer.

If you use a PC - click on 'Help' at the top of your browser window and select the 'About' option

If you use a Mac - with the browser window open, click on the Apple menu and select the 'About' option.

For Flash Cookies (or Local Shared Objects) – The Adobe website provides comprehensive information on how to delete or disable Flash cookies - see http://www.adobe.com/security/flashplayer/.

For Third Party Cookies – If you'd like to opt out of third party company cookies - please use the-opt out tool offered by members of the Network Advertising Initiative (NAI) – see http://www.networkadvertising.org/managing/opt_out.asp.

If you want to know more about Third Party Cookies and to opt out of them if you wish – see www.allaboutcookies.org and www.youronlinechoices.eu.


Our web hosting service provider, Vistaprint, only uses one cookie on Vistaprint hosted websites. Vistaprint uses this cookie to count the number of unique visitors, so they know how many people visit the websites they host and report that to clients via their website dashboard. This cookie is not used for anything else beyond this. It does not use or store any personally identifiable information and other companies who provide websites like Vistaprint, also use similar types of cookies on their customers websites. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us when you choose to contact us. 


You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your own browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website, but this is entirely your choice and responsibility.


Links to other websites


Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.


Controlling your personal information


We will not sell, distribute or lease your personal information to third parties. We will not use any statistical analytics tool to track or to collect any personally identifiable information of the visitors to our site. If you believe that any information we are holding on you is incorrect or incomplete, please email us as soon as possible at: [email protected] . We will promptly correct any information found to be incorrect.

FIN1 THE CONSULTANCY OF CORPORATE GOVERNANCE AND COMPLIANCE (CCGC) LTD

PRIVACY POLICY

This is our updated Privacy Policy effective from 24/04/18.


FIN1 (CCGC) LTD is registered with the Information Commissioner's Office (ICO) under registration reference: ZA352711 and complies with all aspects of the Data Protection Act (DPA).


FIN1 (CCGC) LTD is strongly committed to protecting personal data.  This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights.  It applies to personal data provided to us, both by individuals themselves or by others.  We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.


Personal data is any information relating to an identified or identifiable living person.  FIN1 (CCGC) LTD processes personal data for specific purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose are clearly specified.

When collecting and using personal data, our policy is to be transparent about why and how we process personal data.  

To find out more about our specific processing activities, please go to the relevant sections of this statement.  


Your privacy is vitally important to us.

At FIN1 (CCGC) LTD, we have the following fundamental principles:


We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.

We aim to make it as simple as possible for you to control the personal information we hold about you.
We aim for full transparency on how we gather, use and share your personal information.


Below is FIN1 (CCGC) LTD’s Privacy Policy, which incorporates and clarifies these principles.


Who We Are and What This Policy Covers:


We are a business management consultancy, providing business management, governance, risk and compliance solutions.

We pride ourselves on offering a first class service to our valued clients, which embodies our core values of being personal, focused and transparent.

We strongly believe that our company ethos, of being driven to helping our clients to realise their strategic goals, sets us apart from others within the business management consultancy industry.

This privacy policy applies to information that we collect about you when you ask us to provide you with our specialist services.

Below we explain how we collect, use and share information about you, along with the choices that you have with respect to that information.


Information We Collect


We only collect information about you if we have a legitimate interest in doing so, i.e., to provide you with our services.

We collect information in two ways: when you provide information to us and from outside sources in those circumstances that we need to apply KYC (Know Your Customer) and DD (due diligence) controls.

The information we collect depends on whether you require us to help you with mutually agreed upon consultancy services or provision of services on the basis of a retainer fee.


For all our services we will collect the following information from you directly:

  • Company name
  • Proof of business address 
  • Company registration number
  • Incorporation certificate
  • Passport or ID of the company director(s)   
  • Business insurance certificate 
  • Whether VAT registered
  • VAT registration number 
  • VAT certificate
  • Contact phone number 
  • Email address 
  • Bank details 


How We Use Information


We use the information we gather about you to provide you with our consultancy services. Your information will be shared strictly amongst the consultants at FIN1 (CCGC) LTD and will not be forwarded to other parties. We will always obtain your consent before providing other parties with any of your information.

We like to maintain effective communication with our clients for the duration of the business relationship. Consequently, we will hold your data for as long as we feel that there is a legitimate interest to both parties for us to do so. (NB: You may request that we delete your data at anytime – please see ‘Your Rights’ below)

We will keep in regular contact with you (no less than once every one year) to ensure that we are keeping your information up-to-date.


Sharing Information


We do not sell our clients’ personal information.

We share information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:

We may be required by law to send certain information to HMRC when HMRC contacts us with a formal request.


Security


Whilst it is difficult to guarantee that any method of data storage is 100% secure, we work very hard to protect information about you from unauthorised access, use, alteration, or destruction, and take reasonable measures to do so.


Your Rights


GDPR provides you with the right to request from us access to and rectification or erasure of your personal data or restriction of processing your personal data, or to object to processing.

You also have the right to lodge a complaint with a supervisory authority.

If you have any questions or concerns about how we collect and use your data please contact us at 0207 1998383 or [email protected]


Privacy Policy Changes


Although most changes are likely to be minor, FIN1 (CCGC) LTD may change its Privacy Policy from time to time. FIN1 (CCGC) LTD encourages you to frequently check this page for any changes to its Privacy Policy. If we make changes, we will notify you by revising the change log below and, in some cases, we may provide additional notice (such as adding a statement to our website or sending you a notification through email). Your continued engagement with our consultancy services after any change in this Privacy Policy will constitute your consent to such change.


Change Log


24/04/2018: Revised and reorganised language throughout to help simplify the policy, clarify our practices and ensure GDPR compliance.

Website use


Welcome to our website. If you continue to browse and use this website, you are agreeing to comply with and be bound by the following terms and conditions of use, which together with our privacy policy govern FIN1 (CCGC) LTD’s relationship with you in relation to this website. If you disagree with any part of these terms and conditions, please do not use our website.

The term FIN1 (CCGC) LTD or ‘us’ or ‘we’ refers to FIN1 (CCGC) LTD, which is a Member of Vistaprint Hosting Member Agreement with Vistaprint B.V. for this Website. The term ‘you’ refers to the user or viewer of our website.

The use of this website is subject to the following terms of use:

  • The content of the pages of this website is for your general information and use only. It is subject to change without notice.
  • Neither we nor any third parties provide any warranty or guarantee as to the accuracy, timeliness, performance, completeness or suitability of the information and materials found or offered on this website for any particular purpose. You acknowledge that such information and materials may contain inaccuracies or errors and we expressly exclude liability for any such inaccuracies or errors to the fullest extent permitted by law.
  • Your use of any information or materials on this website is entirely at your own risk, for which we shall not be liable. It shall be your own responsibility to ensure that any products, services or information available through this website meet your specific requirements.
  • This website contains material which is owned by or licensed to us. This material includes, but is not limited to, the design, layout, look, appearance and graphics. Reproduction is prohibited other than in accordance with the copyright notice, which forms part of these terms and conditions.
  • All trademarks reproduced in this website, which are not the property of, or licensed to the operator, are acknowledged on the website.
  • Unauthorised use of this website may give rise to a claim for damages and/or be a criminal offence.
  • From time to time, this website may also include links to other websites. These links are provided for your convenience to provide further information. They do not signify that we endorse the website(s). We have no responsibility for the content of the linked website(s).
  • Your use of this website and any dispute arising out of such use of the website is subject to the laws of England, Northern Ireland, Scotland and Wales.

Disclaimer 


The information contained in this website is for general information purposes only. The information is provided by FIN1 (CCGC) LTD and while we endeavour to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the website or the information, products, services, or related graphics contained on the website for any purpose. Any reliance you place on such information is therefore strictly at your own risk.

In no event will we be liable for any loss or damage including without limitation, indirect or consequential loss or damage, or any loss or damage whatsoever arising from loss of data or profits arising out of, or in connection with, the use of this website.

Through this website you may be able to link to other websites which are not under the control of FIN1 (CCGC) LTD. We have no control over the nature, content and availability of those sites. The inclusion of any links does not necessarily imply a recommendation or endorse the views expressed within them.

Every effort is made to keep the website up and running smoothly. However, FIN1 (CCGC) LTD takes no responsibility for, and will not be liable for, the website being temporarily unavailable due to technical issues beyond our control.