Policies

MAV Systems Ltd are an equal opportunities employer that ensures that all business principles and practices are aligned to legislation but also to the moral compass that guides our success. Supporting ethical material sourcing and environmentally friendly working and production practices, MAV will continue to progress in the provision of the highest quality ANPR cameras whilst maintaining true to our core values and ethical guiding principles.

* “Conflict minerals” originating from the Democratic Republic of the Congo (DRC) are sometimes mined and sold, “under the control of armed groups” to “finance conflict characterized by extreme levels of violence”

Some of these minerals can make their way into the supply chains of the products used around the world, including those in the ANPR manufacturing industry. As part of MAV’s commitment to corporate responsibility and respecting human rights in our own operations and in our global supply chain, it is MAV’s goal to use tantalum, tin, tungsten and gold in our products that do not directly or indirectly finance or benefit armed groups in the DRC or adjoining countries. MAV expects our suppliers to have in place policies and due diligence measures that will enable us to reasonably assure that products and components supplied to us containing conflict minerals are DRC conflict free. MAV expects our suppliers to comply with the Electronic Industry Citizenship Coalition (EICC) Code of Conduct and conduct their business in alignment with MAV’s supply chain responsibility expectations.

In support of this policy, MAV will:

• Exercise due diligence with relevant suppliers consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and encourage our suppliers to do likewise with their suppliers.
• Provide, and expect our suppliers to cooperate in providing, due diligence information to confirm the tantalum, tin, tungsten, and gold in our supply-chain are “conflict free”
• Collaborate with our suppliers and others on industry-wide solutions to enable products that are DRC conflict free.

Adopted: April 2016

Updated: Feb 2021

*”Conflict minerals” as defined by Securities and Exchange Commission (SEC) rules is a broad term which means columbitetantalite (coltan), cassiterite, gold, wolframite, or their derivatives which are limited to tantalum, tin or tungsten, regardless of whether these minerals finance conflict in the Democratic Republic of the Congo (DRC) or adjoining countries.

The EU General Data Protection Regulation (“GDPR”) comes into force across the European Union on 25th May 2018 and brings with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements of the digital age.

The 21st Century brings with it broader use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new Regulation aims to standardise data protection laws and processing across the EU; affording individuals stronger, more consistent rights to access and control their personal information.

Our Commitment

MAV Systems Ltd are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognise our obligations in updating and expanding this program to meet the demands of the GDPR and the UK’s Data Protection Bill.

MAV Systems Ltd are dedicated to safeguarding the personal information under our remit and have developed a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for, the new Regulation. Our preparation for GDPR compliance has been summarised in this statement and include the development and implementation of new data protection duties, policies, procedures, controls and measures to ensure maximum and ongoing compliance.

Planning and Implementation

MAV Systems Ltd already have a consistent level of data protection and security across our organisation and have conducted business wide changes to enhance these measures in line with the demands of GDPR and best practice.

Information Audit – carrying out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.

Policies & Procedures – Revising data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: –

Data Protection – our main policy and procedure document for data protection has been overhauled to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.

Data Retention & Erasure – we have updated our retention policy and schedule to ensure that we meet the ‘data minimisation’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.

Data Breaches – our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.

Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge where appropriate.

Legal Basis for Processing – we have reviewed all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.

Obtaining Consent – we have revised our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.

Direct Marketing – we have revised the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.

Data Subject Rights

In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information via our website, and the foot of this document, of an individual’s right to access any personal information that MAV Systems Ltd processes about them and to request information about: –

• What personal data we hold about them
• The purposes of the processing
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
• The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
• The right to lodge a complaint or seek judicial remedy and who to contact in such instances

Information Security & Technical and Organisational Measures

MAV Systems Ltd takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures, including: –

• Security monitored offices
• Password policy
• Limited Access measures
• Encryptions
• Isolated IT infrastructure
• GDPR Roles and Employees

MAV Systems Ltd have designated Neil Dillon as our Appointed Person and have appointed a data privacy team to implement our roadmap for continuing compliance with the new data protection Regulation.

MAV Systems Ltd understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans.

Should any business wish to find out what information we hold on them, ask for information to be updated or request the removal of any data that we may be in possession of, a dedicated contact email address has been set up – mav.gdpr@mav-systems.com

MAV Systems Limited is committed to the principle of equal opportunities in employment and declares its opposition to any form of less favourable treatment, whether through direct or indirect discrimination accorded to employees or job applicants, on the grounds of age, disability, gender reassignment, marriage or civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation (defined as Protected Characteristics)

MAV Systems Limited recognises its obligations under the Equality Act 2010 and the spirit and intent of any related Codes of Practice:

• for the elimination of discrimination on grounds of sex or marital status and the promotion of equality of opportunity in employment;
• for the elimination of discrimination on grounds of race and the promotion of equality of opportunity in employment;
• for the elimination of discrimination on the grounds of disability and the promotion of equality of opportunity in employment;
• for the elimination of discrimination on the grounds of religion or belief and the promotion of equality of opportunity in employment;
• for the elimination of discrimination on the grounds of sexual orientation and the promotion of equality of opportunity in employment.
• for the elimination of discrimination on the grounds of age and the promotion of equality of opportunity in employment;
• for the elimination of discrimination because they associate with another person who possesses a Protected Characteristic or because others perceive that they have a particular Protected Characteristic, even if they do not.

EMPLOYMENT PRACTICES

MAV Systems Limited states its wholehearted support for the principles and practices of equal opportunity and recognises that it is the duty of all employees to accept their personal responsibility for fostering a fully integrated community at work by adhering to the principles of equal opportunity and maintaining a harmonious working environment.

MAV Systems Limited actively promotes equal opportunities throughout the organisation through the application of employment policies which will ensure that individuals receive treatment that is fair and equitable and consistent with their relevant aptitudes, potential, skills, experiences and abilities. All Managers and Supervisors will seek to ensure that all employees comply with these principles.

MAV Systems Limited will ensure that individuals are recruited and selected, promoted and trained on objective criteria having regard to the relevant aptitudes, potential, skills, experiences and abilities. In particular, no applicant will be placed at a disadvantage by any practices which, although they are applied to all, have the effect of disadvantaging people on the grounds of any Protected Characteristic which is not necessary to the performance of the job or which constitute indirect discrimination. Reasonable adjustments will be taken where a person is put in a detrimental position and such reasonable adjustments remove the detriment.

MAV Systems Limited recognises the problems that harassment may cause at work and is committed to ensure that such unacceptable behaviour does not take place. Harassment is unwanted conduct that violates a person’s dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment for them having regard to all the circumstances including the perception of the victim. All forms of harassment are abhorrent and will not be tolerated by the Company. Harassment in any form is regarded as unlawful discrimination and additionally may also be subject to criminal proceedings.  All such cases will be dealt with under the Disciplinary and Dismissal Procedure.

MAV Systems Limited recognises that the detriment a disabled person endures as a consequence of their disability can, in many instances, be removed by the adoption of reasonable adjustments. The Company is committed to ensure that such adjustments will be affected where reasonably practicable and where the detriment is substantial.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

MAV Systems Ltd has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.

We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, in the coming year we will include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

This policy does not form part of any employee’s contract of employment and we may amend it at any time.

Responsibility for the policy

MAV Systems Ltd has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

MAV Systems Ltd has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

MAV Systems Ltd Privacy Policy

Our contact details

 Name: MAV Systems Ltd

Address: Lullingstone Park Farm Offices, Eynsford, Kent, DA4 0JA

Phone Number: 0300 800 3050

E-mail: anpr@anprcameras.com

The type of personal information we collect

We currently collect and process the following information:

• Personal identifiers, contacts and characteristics which includes name, email address, telephone number, business address and position

How we get the personal information and why we have it

Most of the personal information we process is provided to us directly by you for one of the following reasons:

• Completion of online contact form
• Call to our sales team
• Request for further information via our contact email address

We use the information that you have given us in order to:

• Provide relevant information regarding our products
• Notify recipients of new products or updated information
• Provide technical and customer support

Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:

• Your consent – you are able to remove your consent at any time. You can do this by contacting gdpr@mav-systems.com or calling 0300 800 3050
• We have a legitimate interest

How we store your personal information

Your information is securely stored on our CRM system which offers stringent security measures. The CRM system is only accessible by a limited number of employees who require direct access to information that is required to perform their job role.

We keep contact information for the duration of work partnerships unless requests are received for the removal of any or all information retained. Should a working partnership cease, or a response is not received to relevant information sent within a 12 month period, all information pertaining to an individual will be deleted from the CRM system with no further correspondence attempted.

Your data protection rights 

Under data protection law, you have rights including:

Your right of access – You have the right to ask us for copies of your personal information.

Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

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

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

Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.

Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at mav.gdpr@mav-systems.com or 0300 800 3050 if you wish to make a request.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at mav.gdpr@mav-systems.com or 0300 800 3050.

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

MAV Systems Ltd (MAV) aim to minimise any business activity which may have an adverse effect on the environment.

When applicable, MAV’s contractors and agents shall be required to comply with all relevant legislation and codes of practice relating to environmental issues.

Recycling

The main type of waste produced by MAV is waste paper and packaging and, where possible, will undertake to isolate and dispose of recyclable materials so that they can be recycled by the appropriate company/council service.

MAV promotes the use of recycled materials and the use of environmentally safe products.

Where practicable, all staff shall co-operate with suppliers’ recycling initiatives.

Energy Efficiency

The office lighting and heat/cooling at MAV offices shall be set for maximum efficiency that also maintains best working conditions and comfort levels for staff.  The maintenance of any hot water systems, boilers and air conditioning units shall be scheduled to maximise their energy efficiency by specialist and competent contractors. All appliances bought by the Company shall have A rating unless dispensation is agreed by the Managing Director.

Hazardous Waste

The Hazardous Waste Regulations requires that MAV disposes of all hazardous waste on site in the correct manner and staff will be trained to identify such materials and arrange appropriate disposal.

Steve Walker

Managing Director

Updated and reissued 20th July 2021

All employees must read this policy and adhere to its guidelines.

It is the duty of MAV Systems Ltd (MAV) to comply with the obligations under the Health and Safety at Work Act 1974 (as amended), the Management of Health and Safety at Work Regulations 1999 (as amended) and if applicable any other supporting legislation concerning Health & Safety.

At all times MAV will endeavour to provide and maintain a healthy and safe working environment for its employees, visitors and contractors and the local community who may be affected by our operations.

The objective of the Company’s Health and Safety Policy is to minimise and control the number of occupational accidents, illnesses and near-misses in the workplace. Appropriate resources will be made available to achieve this aim. In particular, the Company has a responsibility to:

• Provide and maintain a safe working environment with appropriate workspaces/desks, seating, welfare facilities and access/egress.
• Make provisions for the safe handling, storage and transport of articles and substances.
• Provide information, instruction, training and supervision to enable employees to perform their work safely and efficiently.
• Consult with employees on Health and Safety related matters.
• Demonstrate commitment by Senior Management to Health and Safety.
• Review and revise Health & Safety arrangements in the workplace.

The Company firmly believes that the success of its Health and Safety Policy can only be achieved through the cooperation of all personnel. It is also the duty of each employee to take reasonable care of his/her own welfare and to report any situation which may potentially endanger the well being of them or others on site to a Senior Manager or Director.

This Policy will be continually monitored and improvements to the policy will be implemented as and when required.

Steve Walker

1.1 This anti-bribery policy exists to set out the responsibilities of MAV Systems Ltd and those who work for us in regards to observing and upholding our zero-tolerance position on bribery and corruption.

1.2 It also exists to act as a source of information and guidance for those working for MAV Systems Ltd. It helps them recognise and deal with bribery and corruption issues, as well as understand their responsibilities.

2. Policy statement

2.1 MAV Systems Ltd is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented. MAV Systems Ltd has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.

2.2 MAV Systems Ltd will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, in regards to our conduct both at home and abroad.

2.3 MAV Systems Ltd recognises that bribery and corruption are punishable by up to ten years of imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business, and take our legal responsibilities seriously.

3. Who is covered by the policy?

3.1 This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK). The policy also applies to Officers, Trustees, Board, and/or Committee members at any level.

3.2 In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.

3.3 Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to anti-bribery and corruption.

4. Definition of bribery

4.1 Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision.

4.2 A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.

4.3 Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.

4.4 Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company’s compliance manager.

5. What is and what is NOT acceptable

5.1 This section of the policy refers to 4 areas:

• Gifts and hospitality.
• Facilitation payments.
• Political contributions.
• Charitable contributions.

5.2 Gifts and hospitality

MAV Systems Ltd accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements:

a. It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits.

b. It is not made with the suggestion that a return favour is expected.

c. It is in compliance with local law.

d. It is given in the name of the company, not in an individual’s name.

e. It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).

f. It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).

g. It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.

h. It is given/received openly, not secretly.

i. It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.

j. It is not above a certain excessive value, as pre-determined by the company’s compliance manager (usually in excess of £100).

k. It is not offer to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s compliance manager.

5.3 Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted so long as it is declared to the compliance manager, who will assess the circumstances.

5.4 MAV Systems Ltd recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each.

5.5 As good practice, gifts given and received should always be disclosed to the compliance manager. Gifts from suppliers should always be disclosed.

5.6 The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the compliance manager should be sought.

5.7 Facilitation Payments and Kickbacks

MAV Systems Ltd does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action.

5.8 MAV Systems Ltd does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.

5.9 MAV Systems Ltd recognises that, despite our strict policy on facilitation payments and kickbacks, employees may face a situation where avoiding a facilitation payment or kickback may put their/their family’s personal security at risk. Under these circumstances, the following steps must be taken:

a. Keep any amount to the minimum.

b. Ask for a receipt, detailing the amount and reason for the payment.

c. Create a record concerning the payment.

d. Report this incident to your line manager.

5.10 Political Contributions

MAV Systems Ltd will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage.

5.11 Charitable Contributions

MAV Systems Ltd accepts (and indeed encourages) the act of donating to charities – whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes.

5.12 Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery.

5.13 We will ensure that all charitable donations made are legal and ethical under local laws and practices, and that donations are not offered/made without the approval of the compliance manager.

6. Employee Responsibilities

6.1 As an employee of MAV Systems Ltd, you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other anti-bribery and corruption information you are given.

6.2 All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy.

6.3 If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must notify the compliance manager.

6.4 If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. MAV Systems Ltd has the right to terminate a contractual relationship with an employee if they breach this anti-bribery policy.

7. What happens if I need to raise a concern?

7.1 This section of the policy covers 3 areas:

a. How to raise a concern.

b. What to do if you are a victim of bribery or corruption.

c. Protection

7.2 How to raise a concern

If you suspect that there is an instance of bribery or corrupt activities occurring in relation to MAV Systems Ltd, you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behaviour can be considered bribery or corruption, you should speak to your line manager, the compliance manager, the director, or the Head of Governance and Legal.

7.3 MAV Systems Ltd will familiarise all employees with its whistleblowing procedures so employees can vocalise their concerns swiftly and confidentially.

7.4 What to do if you are a victim of bribery or corruption

You must tell your compliance manager as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity.

7.5 Protection

If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of bribery or corruption, MAV Systems Ltd understands that you may feel worried about potential repercussions. MAV Systems Ltd will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken.

7.6 MAV Systems Ltd will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption.

7.7 Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in relation to the concern the individual raised.

7.8 If you have reason to believe you’ve been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, you should inform your line manager or the compliance manager immediately.

8. Training and communication

8.1 MAV Systems Ltd will provide training on this policy as part of the induction process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy, and will be asked annually to formally accept that they will comply with this policy.

8.2 MAV Systems Ltd’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third-parties at the outset of business relations, and as appropriate thereafter.

8.3 MAV Systems Ltd will provide relevant anti-bribery and corruption training to employees etc. where we feel their knowledge of how to comply with the Bribery Act needs to be enhanced. As good practice, all businesses should provide their employees with anti-bribery training where there is a potential risk of facing bribery or corruption during work activities.

9. Record keeping

9.1 MAV Systems Ltd will keep detailed and accurate financial records, and will have appropriate internal controls in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given, and understand that gifts and acts of hospitality are subject to managerial review.

10. Monitoring and reviewing

10.1 MAV Systems’ compliance manager is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness.

10.2 Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice.

10.3 Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the compliance manager.

10.4 This policy does not form part of an employee’s contract of employment and MAV Systems Ltd may amend it at any time so to improve its effectiveness at combatting bribery and corruption.

As part of The Traffic Group, MAV Systems Ltd is an accredited Living Wage employer. The Living Wage is an hourly rate set independently and updated annually and is calculated according to the basic cost of living in the UK.

There are two rates of Living Wage: one for those based in Greater London (London Living Wage) and another rate for the rest of the UK (UK Living Wage).  The Living Wage is an hourly rate set independently and updated annually by the Living Wage Foundation. The Living Wage is calculated according to the real costs of living, based on a basket of household goods and services. It is intended to allow people to provide for themselves and their families.

Introduction

Employers choose to pay the Living Wage on a voluntary basis as opposed to the National Minimum Wage and the National Living Wage which are statutory obligations.  We strive to make the community we operate in a better place and is of the view that payment of a Living Wage can have a positive impact on the delivery of services as well as economic and social benefits.  We are also committed to providing quality products and services to our customer, rewarding our employees for their commitment to this objective is part of MAV’s core principles.

Living Wage Benefits

MAV Systems Ltd recognises payment of the Living Wage has many advantages and these include:

• Staff retention and reduced turnover
• Reduction in absenteeism
• Heightened employee engagement
• Increased commitment to organisation
• Ethical employment practices
• Reduction in poverty affording people the opportunity to provide for themselves and their families

Living Wage Commitments

For MAV Systems Ltd being a Living Wage employer means the following:

• We will continue to pay the Living Wage for all our directly employed staff.
• We will increase the Living Wage paid if amended nationally (subject to budget) and implement as soon as possible.
• We will aim to encourage and promote, on a case-by-case basis, that all employees of our UK supplier chain be paid the Living Wage.