Privacy Policy

Last updated: August 22, 2024

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. This Privacy Policy has been created with the help of the Privacy Policy Generator.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Ltd, 8 Avondale Road Wolverhampton WV6 0AJ.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• Country refers to: United Kingdom
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Personal Data is any information that relates to an identified or identifiable individual.
• Service refers to the Website.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Website refers to GM2 Safer Security ltd, accessible from gm2safersecurity.co.uk
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Information from Third-Party Social Media Services

The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:

• Google
• Facebook
• Instagram
• Twitter
• LinkedIn

If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service’s account, such as Your name, Your email address, Your activities or Your contact list associated with that account.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service’s account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. You can learn more about cookies on TermsFeed website article.

We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential CookiesType: Session CookiesAdministered by: UsPurpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
• Cookies Policy / Notice Acceptance CookiesType: Persistent CookiesAdministered by: UsPurpose: These Cookies identify if users have accepted the use of cookies on the Website.
• Functionality CookiesType: Persistent CookiesAdministered by: UsPurpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.
• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
• With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data 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 Data, We cannot guarantee its absolute security.

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By email: Info@gm2safersecurity.co.uk
• By phone number: 07467 271371

Generated using TermsFeed Privacy Policy Generator

GM2 Safer Security ltd is aware of its obligations under the General Data Protection Regulation (GDPR) and is committed to processing your data securely and transparently.

This privacy notice sets out, in line with GDPR, the types of data that we hold on you as a Client of GM2 Safer Security ltd. It also sets out how we use that information, how long we keep it for and other relevant information about your data.

This notice applies to current and former Clients, workers and contractors.

Data Controller Details

 GM2 Safer Security Is a data controller, meaning that it determines the processes to be used when using your personal data. Our Contact details are as follows:

GM2 Safer Security ltd, 33-35 Tottenham Road, Wolverhampton WV3 9NB.

Data Protection Principles

In relation to your personal data, we will:

• Process it fairly, lawfully and in a clear, transparent way
• Collect your data only for reasons that we find proper for the course of your employment in ways that have been explained to you
• Only use it in the way that we have you about
• Ensure it is correct and up to date Keep your data for as long as we need it
• Process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed

Types of Data we process

We hold many types of data about you, including the following:

• Your personal details including your name, email address, phone numbers
• Gender
• CCTV footage

How We Collect Your Data

We collect data about you in a variety of ways and this will usually start when we commence the service where we will collect the data directly from you. Personal data is kept in contract files or within the Company’s CRM Database.

Why we Process Your Data

The law on data protection allows us to process your data for certain reasons only:

• In order to perform the service contract that we are party to
• In order to carry out legally required duties
• In order for us to carry out our legitimate interests
• To protect your interests and
• Where something is done in the public interest

All other processing carried by us falls into one of the permitted reasons. Generally, we rely on the first three reasons set out above to process your data. For example, we need to collect your personal data in order to:

• Carry out the service contract that we have entered into with you

We also collect data so that we can carry out activities which are in the legitimate interests of GM2 Safer Security Ltd. We have set these out below:

• Providing contractual benefits to you
• Maintaining comprehensive up to date personnel records about you to ensure, amongst other things, effective correspondence can be achieved and appropriate contact points in the event of an emergency are maintained
• Dealing with legal claims made against GM2 Safer Security Ltd 
• Preventing fraud

Special Categories of Data

Special categories of data are not applicable under this contract

If you do not Provide your Data to us
One of the reasons for processing your data is to allow us to carry out our duties in line with your contract of service. If you do not provide us with the data needed to do this, we will be unable to perform those duties e.g. informing you of onsite incidents.

Sharing your Data

• Your data will be shared with colleagues within GM2 Safer Security Ltd 

where necessary for them to undertake their duties. This includes for example, response officers.
We may also share your data with third parties to comply with a legal obligation upon us.
We do not share your data with bodies outside the European Economic Area.

Protecting Your Data

We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such as ended.

How Long We Keep Your Data for

In line with data protection principles, we only keep your data for as long as we need it for, which will be at least for the duration of the contract or contract review.

Name: Term of Contract or Informed Otherwise
Emails: Term of Contract or Informed Otherwise
Contact Numbers: Term of Contract or Informed Otherwise

Yours Rights in Relation to your Data

The law on data protection gives you certain rights in relation to the data we hold on you. These are:

• The right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice.
• The right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it.
• The right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it.
• The right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data it correct.
• The right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests.

Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some case, we may continue to use the data where so permitted by having a legitimate reason for doing so.

If you wish to exercise any rights explained above, please contact the Data Protection Officer within GM2 Safer Security Ltd. 

Making a Complaint

The supervisory authority in the UK for data protection matters is the Information Commissioner (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO.

Data Protection Officer

If you would like to contact GM2 Safer Security Ltd.

   in relation to your data privacy please contact us at: gm2@gmail.co.uk.

Personal Data

If you have any questions about the data we hold on your behalf, we will do our best to answer them.

If you have a specific enquiry about the data we hold, or want to see the data we hold, please fill in the form below. You can also call us on 07513681227 or 07497047291, or send a request in writing to:

The Data Privacy Team
33-35 Tottenham Road Wolverhampton WV3 9NB.

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Corporate Social Responsibility

The Living Wage Foundation – Recognised Service Providers

What Is the Real Living Wage?

The real Living Wage is an independently calculated rate of pay that is based on the cost of living. At the heart of the Living Wage movement is a simple idea – that a hard day’s work deserves a fair day’s pay. In 2016 the government introduced a rise in the minimum wage for over 25s, they called this new statutory minimum the ‘National Living Wage’.

However, this is not based on the real cost of living. That’s why thousands of UK employers have voluntarily committed to going further, by paying all their staff the real Living Wage. The real Living Wage is based on the actual cost of living, taking into account the cost of housing, food, travel and other essentials. It enjoys cross party support and is paid by thousands of employers, including over one third of the FTSE 100.

Fairness Inclusion & Respect (GM2)

Promoting a culture of fairness, inclusion and respect supports our mission; ‘To provide our customers with the best service and innovation, through supporting our employees and creating a culture of inclusion and happiness’ and brings many business benefits to the companies that work to achieve it. As a business, we have embraced FIR to attract, recruit, train and retain the skills needed to make Security & FM a career of choice for our people. Clients and large contractors are increasingly expecting their supply chain partners to work with them to achieve this.

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Modern Slavery & Human Trafficking Statement

This statement sets out GM2 Safer Security Ltd’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 August 2019 to 31st July 2020. It is noted that there is no legal obligation to publish this statement as required by the Modern Slavery Act 2015.

As part of the manpower services, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The organisation is totally committed to preventing slavery and human trafficking in its manpower service activities, and to ensuring that its supply chains albeit predominately United Kingdom based and small are free from slavery and human trafficking.

Organisational Structure and Supply Chains

This statement covers the activities of GM2 Safer Security Ltd:

• We are an independent manpower provider to the infrastructure, construction and facilities management sectors. The organisation was founded in 2024 and develops partnerships with its clients, understanding their service needs and strategy that lead to provision of bespoke solutions to meet expectations.
• The organisation’s workforce is employed on permanent and temporary Pay As You Earn (PAYE) contractual basis. All right to work, residency, competence cards/certificates and employment history verification checks are conducted in accordance with the Immigration, Asylum and Nationality Act 2006, British standards and Quality Management Systems procedure requirements.

The organisation currently operates in the following countries

• United Kingdom

Risk Assessment

There are no activities that are at high risk of slavery or human trafficking. Through the supplier/procurement code of conduct the organisation will ensure that all suppliers also adhere to the Modern Slavery Act 2015.

Responsibility

Responsibility for the organisation’s anti-slavery initiatives is as follows:

• Policies: Managing Director and Contracts Director
• Investigations/Due Diligence: The Contracts Director and Compliance Director are responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking.
• Training: The Contracts Director and Compliance Director are responsible for ensuring that the awareness of slavery and human trafficking risks are communicated throughout the organisation and through the supply chain.

Relevant Policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

• Employee Concerns (Whistleblowing) Policy: The organisation encourages all its stakeholders to report any concerns related to the direct activities. This can include any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s policy is designed to make it easy for workers to make disclosures, without fear of retribution. Employees, customers or others who have concerns can report any activities associated to slavery and human trafficking by contacting their immediate line manager, Human Resources or confidentially to the Managing Director via the website.
• Employee Code of Conduct: The organisation’s code makes it clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour.
• Supplier/Procurement Code of Conduct: The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. As part of the supply chain selection process all potential and existing suppliers are required to complete a Supplier Questionnaire to assess their suitability as a supplier. Within the Supplier Questionnaire all suppliers are required to provide evidence of their compliance towards Labour Standards and the Asylum & Immigration Act 2006. This enables the procurement team to identify any potential risks to the quality of the service provision or goods being provided by the supplier and prevent any slavery or human trafficking. All suppliers are audited against the supplier code of conduct.
• Recruitment Policy: The organisation only employs people on a permanent or temporary PAYE contractual basis. Prior to commencement of employment all employees are subject to right to work, residency, competence cards/certificates and employment checks in accordance with the Immigration Asylum and Nationality Act 2006 and British standards Quality Management System procedures. The Recruitment Policy is compliant to all EU and UK legislation, including the minimum wage and therefore is not at risk of slavery and human trafficking.
• Corporate Social Responsibility Policy: The organisation’s Corporate Social Responsibility Policy covers the responsibilities of the Board of Directors and its commitment towards the external Environment, Health & Safety, Workplace and assurance to the supply chain code of conduct. The Policy is communicated to the whole workforce and forms part of the induction programme.
• Anti-Bribery/Fraud Policy: The organisation’s Anti Bribery Policy aims to prevent any form of bribery being committed within the organisation and by any stakeholder(s) associated with its business. We foster a culture of integrity where bribery is unacceptable. This policy is communicated to all employees and forms part of the induction programme.

Due Diligence

The organisation undertakes due diligence when considering taking on new suppliers and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include:

• evaluating the modern slavery and human trafficking risks of each new supplier in accordance with the supply chain selection process.
• conducting supplier audits by our Compliance Manager, which have more focus on personnel management and slavery and human trafficking where general risks are identified.
• If required, invoke sanctions against suppliers that fail to improve their performance or seriously violate our supplier code of conduct.

Performance Indicators

To comply with the Modern Slavery Act 2015, the organisation:

• Reviews its existing supply chains by the end of the financial year, to ensure their compliance to the Modern Slavery Act 2015.
• Awareness training is provided to all Directors, Managers, Supervisors and staff within the organisation as a module within the organisation’s induction, toolbox talks, management development and refresher programmes.

The organisation’s modern slavery awareness training covers:

• our business’ purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline.
• how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available.
• how to identify the signs of slavery and human trafficking.
• what initial steps should be taken if slavery or human trafficking is suspected.
• how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation.
• what external help is available, for example through the Modern Slavery Helpline, Gang-masters Licensing Authority and “Stronger together” initiative.
• what steps the organisation should take if suppliers or contractors do not implement antislavery policies in high-risk scenarios, including their removal from the organisation’s supply chains.

Awareness-Raising Programme

As well as training staff, the organisation raises awareness of modern slavery issues by maintaining flyers/bulletins on the intranet portal.

The flyers/bulletins explain to staff:

• the basic principles of the Modern Slavery Act 2015.
• what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
• what external help is available, for example through the Modern Slavery Helpline. of conduct.

GM2 Member Approval

This statement has been approved by the GM2 organisation directors, who will review and update it annually.

Anti-Bribery Policy Statement

The Bribery Act 2010 modernises the law on bribery. It came into force on 1 July 2011.

The purpose of this policy is to set out for GM2 members and employees of the company the aim of limiting GM2 Safer Security exposure to bribery by:

• Setting out a clear anti-bribery policy
• Training all employees and Board members so that they can recognise and avoid the use of bribery by themselves and others
• Encouraging its employees to be vigilant and to report any suspicions of bribery, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately
• Rigorously investigating instances of alleged bribery and assisting police and other appropriate authorities in any resultant prosecution
• Taking firm and vigorous action against any individual(s) involved in bribery

Scope

This policy applies to all who work or represent, including suppliers and subcontractors, in any way GM2 Safer Security.

The company prohibits

• The offering, the giving, the solicitation, or the acceptance of any bribe, whether cash or other inducement

To or from

• Any person or company, wherever they are situated

By

• Any individual employee, Board Member, agent or other person or body.

In order to

• Gain any commercial, contractual, or regulatory advantage for the Company in a way which is unethical

Or in order to

• Gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual

Further clarification

This policy statement prohibits any inducement which results in a personal gain or advantage to the recipient, or any person or body associated with them, and which is intended to influence them to take action which may not be solely in the interests of the Company or of the person or body employing them or whom they represent.

This policy is not meant to prohibit the following practices providing they are customary in a particular market, are proportionate and are properly recorded and in line with The Bribery Act 2010:

• Normal and appropriate hospitality
• The giving of a ceremonial gift on a festival or another special time
• The use of any recognised fast-track process which is available to all on payment of a fee
• The offer of resources to assist the person or body to make the decision more efficiently provided that they are supplied for that purpose only

Inevitably, decisions as to what is acceptable may not always be easy. If anyone is in doubt as to whether a potential act constitutes bribery, the matter should be referred to your Line Manager. If necessary, guidance should also be sought from a director.

Employee and board responsibility

The prevention, detection and reporting of bribery is the responsibility of all employees, Directors, and Management. Suitable channels of communication by which employees and others can report confidentially any suspicion of bribery will be maintained by the Whistleblowing procedure.

Signed by: Abdoulie Camara.