Legal

Contis Group – Security & Privacy Policy

Contis Financial Services or a Contis Group company or third party acting on its behalf (“We”) are committed to protecting and respecting your privacy.

This policy (together with our cookie policy and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting any of our sites, you are accepting and consenting to the practices described in this policy.

For the purpose of the Data Protection Act 1998 (the Act), the data controller is Contis Financial Services and all Contis Group companies of Navigation House, Belmont Wharf, Skipton, North Yorkshire, BD23 1RL. “We” are registered on the public register of data controllers maintained by the Information Commissioner and are licensed to hold information and must comply with the Act at all times.

What information we collect from you and how we use it

We may collect and process your personal contact details:
Information you give us
You may give us information about you by filling in forms on our site, social media logins and/or other plugins, or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use our site, subscribe to a newsletter or service, order products or services, upload content, and/or participate in discussion boards or other social media functions on our site. The information you give us may include (but is not necessarily limited to):

  • your personal name and address;
  • your business name and address;
  • your email address;
  • your phone number;
  • your mobile number;
  • your photograph;
  • Information collected to verify your identity including our date of birth;
  • You may be asked to provide a password to utilise some online services such as your account facility.

How we use your information

We use your information to give you to access the content and functions available via the site. Additionally it will be used for the purposes described in the terms and conditions of your relevant product and service. We will also use the information to enable us to notify you about any changes, reviews or improvements to our products and services.
We will disclose your information to:
Fraud prevention, identity verification and other organisations for the purposes of preventing fraud and money laundering;
Our group companies, third party service providers and agents in order to provide the products and services;
Other third parties, with your agreement, whose products and services may be of interest to you. If we transfer your information to third parties outside of the European Union we may take steps to ensure that the third party agrees to apply the same levels of protection that apply in the UK.

The information we collect about you

Each time you visit our site or interact with the emails we send to you, we may automatically collect the following information:

  • Technical information: including the Internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, operating system and platform;
  • Information about your visit, including the URL clickstream to, through and from our site (including date and time); pages, resources and/or products you viewed or searched for; page response times, errors, length of visits to certain pages, page interaction, and methods used to browse away from the page;
  • Information about your interaction with our emails, including whether you have opened the email, the number of times the email is accessed, and your interaction with email content including the links you have clicked.

How we use your information

We use your information to:

  • Administer our site and for internal operations including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • Make improvements to our site;
  • Measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  • Make suggestions and recommendations to you and other users of our site about content, products/services that may interest you or them.

The information we receive from other sources

We may receive information about you if you use any of the other websites or any of our group companies or the other services we provide.

We are also working closely with third parties (including, for example sub-contractors in technical, payment and delivery services; credit reference and marketing agencies) and you may receive information about you from them.

How we use your information

We may combine the information you give us, and the information collected when you visit our site to improve our products/service for you and other users. We may make suggestions or recommendations to you or other users about content, product/services that may interest you or them.

We will not ask for personal information by insecure methods. When asking for personal information over the phone we will perform identity checks using information you have supplied or information only you may know.

Accessing your information

At any time you may request we provide you with all the information we hold about you except for your password and PIN (which we cannot access). You can contact us to request this information using the ‘Contacting us’ details at the bottom of this policy. There will be an administration charge of £10 for providing this information. The data may be provided in printed or electronic format but we will not email this information.

Protecting your information

Your data is secured by encryption, firewalls and Secure Socket Layer (SSL) technology. This is industry standard encryption technology which manages the security of messages transmitted across the internet. When we receive your data, we store it on secure servers which can only be accessed by us. We store your passwords using one way encryption which means we do not know what your password is.
Like any other website, we cannot guarantee it will be fault free and do not accept any liability for the loss, theft or misuse of your personal details.

Storing your data within and outside the EEA

The data that we collect from you may be transferred to an external third party hosting company (i.e. who works for us, our related companies and companies who we have contracted to process or store data on our behalf) within the European Economic Area (“EEA”). It can also be transferred to and stored at a destination outside the EEA. Please note that privacy laws in countries outside of the EEA may not be the same as, and in some cases may be less protective, ‘Personal Data’ may be subject to lawful access requests by government agencies.

By submitting your personal data you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Social media

If you connect or integrate any social media services with services we provide, you may receive social notifications either from us or from third party companies providing social media services on our behalf. You can manage these social notifications through changing your privacy settings on the relevant social media site or discontinuing any interaction. If you register and provide information to a forum or blog, the information you provide will be published for anyone to see or where you create a connection between Contis Group services and third party sites, we may collect, use, disclose, transfer and store/retain information relating to your account with such third party services in accordance with this Privacy Policy.

Our cookie usage

Our website uses cookies to distinguish you from other users; and to ultimately help improve your user experience.
Cookies are small text files which are downloaded to your device when you visit our website or application. The website or application may retrieve these cookies from your web browser each time you visit, so they can recognise you, remember your preferences and provide you with a more secure or improved online experience. They do not save any sensitive information about you. For further information go to Contis’ cookie policy or to know more about how cookies work and can be managed, then go to www.allaboutcookies.org.

What are cookies?

Cookies are small text files which are downloaded to your device when you visit a website or application. The website or application may retrieve these cookies from your web browser each time you visit, so they can recognise you, remember your preferences and provide you with a more secure or improved online experience. They do not contain or save any sensitive information about you:

  • They don’t store your name
  • They don’t store your address
  • They don’t store any payment details
  • You will not receive any calls or mail as a result of a cookie

By continuing to use our website, you are agreeing to use our cookies; alternatively you can manage them in your browser setting (see Managing Cookies). NB. If you decide to disable them, then you may not be able to access many of the features within our website and access areas like your account.

Our cookies and what they do for you?

When you use our website, the following four types of cookie may be set on your device:

This cookie list is kept up-to-date as possible.

Managing cookies

Your chosen browser will offer cookie management options within their tools. You can set the browser to accept cookies only from specific websites (e.g. this website). More importantly, browsers can also enable you to delete specific cookies. It is even possible to set a browser to reject all cookies. Please be aware that if you choose to block all cookies, our site will not function as intended and you will not be able to use or access many of the services we provide. Rather than blocking all cookies, you can choose to only block third-party cookies which will still allow our website to function as intended.

Third party links

As you browse our website you may click on third party links. Contis is not responsible for the content or privacy polices of any linked websites. You should check the individual privacy polices accordingly. We will be happy to clarify any information we hold on you, if you make a formal written request. You can then check, update or delete your details accordingly.

For more information

You can learn more about the use of cookies by visiting: www.aboutcookies.org

1-Executive Summary

This policy explains the procedures through which Contis can maintain its high ethical standards and protect its reputation against any allegations of bribery and corruption. Its successful implementation requires proactive adoption and compliance by each of its employees.

It will be communicated to all employees of Contis and its subsidiaries (including Contis India), as well as relevant business partners and other necessary individuals and entities. Those who work in areas within our business identified as being particularly high risk will receive additional training and support in identifying and preventing corrupt activities.

2-Introduction

It is Contis’ policy to conduct business in a legal, honest and ethical way and without the use of corrupt practices or acts of bribery to obtain an unfair advantage. Bribery and corruption harms the societies in which these acts are committed and prevents economic growth and development.

Bribery is a criminal offence in most countries in which Contis operates and corrupt acts expose us and our employees to a risk of prosecution, fines and imprisonment, as well as endangering our corporate reputation.

This policy has been adopted by Contis Group main board and is to be communicated to everyone involved in our business to ensure their commitment to it. The board attaches the utmost importance to this policy and will apply a “zero tolerance” approach to acts of bribery and corruption by any of our employees or by business partners working on our behalf. Any breach of this policy will be regarded as a serious matter by the Company and is likely to result in serious disciplinary sanctions, which could ultimately lead to dismissal.

3-What is ‘bribery and corruption’?

Broadly, bribery is the offer, promise, giving, demanding or acceptance of a financial or other advantage as an inducement or reward for an action which is illegal, unethical or a breach of trust. For example, a bribe could be a promise of anything of value, the offer or receipt of any kickback, loan, fee, reward or other advantage or even the giving of donations or charitable aid –in any case where it is designed to exert improper influence (e.g. in the award of a sales contract).

Corruption, broadly, is the misuse of public office or power for private gain; or misuse of private power in relation to business outside the realm of government.

Acts of bribery or corruption are designed to influence the individual in the performance of their duty and incline them to act dishonestly. For the purposes of this policy, whether the payee or recipient of the act of bribery or corruption works in the public or private sector is irrelevant.

The person being bribed is generally someone who will be able to obtain, retain or direct business. This may involve sales initiatives or promotions (e.g. in the award of a sales contract); or, it may simply involve the handling of administrative tasks such as licenses, customs, taxes or import/export matters by a public official. It does not matter whether the act of bribery is committed before or after the tendering or award of a contract or the completion of administrative task by a public official.

4-What does the law say about bribery and corruption?

Bribery and corrupt behaviour can be committed by:

  1. an employee, officer or director
  2. any person acting on behalf of Contis (e.g. our business partners, agents or associates)
  3. individuals and organisations where they authorise someone else to carry out these acts

Bribery is a criminal offence in most countries in which Contis operates and penalties can be severe. In the UK the Bribery Act 2010 not only makes bribery and corruption illegal, but also holds UK companies liable for failing to implement adequate procedures to prevent such acts by those working for the company or on its behalf, no matter where in the world the act takes place. In addition, current US legislation offers similar prohibitions and potential penalties and is enforced with vigour by the US authorities. It is therefore in your interests, as well as those of Contis, that you act with propriety at all times. Corrupt acts committed abroad, including those by business partners or associates working on our behalf, may well result in a prosecution at home.

5-What steps can be taken to prevent bribery and corruption?

We can take the following steps to assist in the prevention of bribery and corruption:

A-Risk Assessment

Effective risk assessment lies at the very core of the success or failure of this policy. Risk identification pinpoints the specific areas in which we face bribery and corruption risks and allows us to better evaluate and mitigate these risks and thereby protect ourselves. Local management must assess the vulnerability of each business unit to these risks on an ongoing basis, subject to review by the Compliance Manager. Risk assessment is intended to be an ongoing process with continuous communication between local management and the Compliance Manager.

B- Accurate books and record-keeping

Many serious global bribery and corruption offences have been found to involve some degree of inaccurate record-keeping. We must ensure that we maintain accurate books, records and financial reporting within all Contis business units and for significant business partners working on our behalf. Our books, records and overall financial reporting must also be transparent i.e. they must accurately reflect each of the underlying transactions. False, misleading or inaccurate records of any kind could potentially damage the Company.

C- Effective monitoring and internal control

Our businesses must all maintain an effective system of internal control and monitoring of our transactions. Once bribery and corruption risks have been identified and highlighted via the risk assessment process, procedures can be developed in order to help mitigate these risks on an ongoing basis.

Each business unit manager must ensure that the business for which he/she is responsible engages in effective risk assessment and implements the necessary steps to prevent bribery and corruption. As these steps will vary by geography and business unit, such members should consult with the Compliance Manager who will provide guidelines and principles for the identification, mitigation and monitoring of these risks.

Ultimate responsibility for preventing bribery and corruption belongs with the Managing Director of Contis Group.

6-Where do the bribery and corruption risks typically arise?

A-Use of Business Partners

The definition of a business partner is broad, and could include suppliers, resellers, strategic or channel partners or others who act on behalf of all who provide services to the Company. Whilst the use of business partners can help us reach our goals, we need to be aware that these arrangements can potentially present Contis with significant risks.

Risks can be identified where a business partner conducts activities on behalf of Contis, so that the result of their actions can be seen as benefiting Contis. Business partners who act on our behalf must be advised of the existence of and operate at all times in accordance with this policy. Local management is responsible for the evaluation of each relationship and determine whether or not it falls into this category.

Where special risk regarding a business partner or arrangement has been identified, the relevant Business Unit manager in conjunction with support from the Compliance Manager, must:

  • evaluate the background, experience and reputation of the business partner
  • understand the services to be provided, and methods of compensation payment
  • evaluate the business rationale for engaging the business partner
  • take reasonable steps to monitor the transactions of business partners appropriately
  • ensure there is a written agreement in place which acknowledges the business partners understanding and compliance with this policy

B-Gifts, entertainment and hospitality

Gifts, entertainment and hospitality includes the receipt or offer of gifts, meals or tokens of appreciation and gratitude, or invitations to events, functions, or other social gatherings, in connection with matters related to our business. These activities are acceptable provided they fall within reasonable bounds of value and occurrence.

In order to evaluate what is “acceptable” it is worth asking yourself the following:

  • What is the intent? Is it to build a relationship or is it something else?
  • How would this look if these details were on the front of the newspaper?
  • What if the situation were to be reversed – would there be a double standard?

If you find it difficult to answer one of these questions, there may be a risk involved which could potentially damage our reputation and business and the action could well be unlawful.

Although no two situations are the same circumstances which are never permissible include examples that involve:

  • a ‘quid pro quo’ (offered for something in return)
  • gifts in the form of cash or cash equivalent vouchers
  • entertainment of a sexual or similarly inappropriate nature

As a general rule, Contis employees and business partners should not provide gifts to or receive them from any government official (or their close families and business associates). However, we do understand that in certain countries gift giving and receiving with these individuals is a cultural norm. If you are faced with such a situation please consult the Compliance Manager before proceeding.

Circumstances that are usually acceptable include:

  • modest/occasional meals with someone with whom we do business
  • occasional attendance at ordinary sports, theatre and other cultural events
  • gifts of nominal value, such as pens, or small promotional items

A variety of cultural factors such as customs, currency and expectations may influence the level of acceptability. If you feel uncertain at any time regarding cultural acceptability of gifts, entertainment or hospitality, please consult the Compliance Manager. In addition, if an example does not fall under the above categories, please in the first instance seek guidance from the Compliance Manager. Generally, such examples would not be permissible without prior approval.

Contis Group will be required to maintain and monitor its gifts, entertainment and hospitality register. Any form of gift, entertainment or hospitality given, received or offered – which meets or exceeds the equivalent of £100 in value (or, if less individually, exceeds £200 in aggregate from the same or related source in any 12 month period)– must be appropriately recorded in the register. In the event that an impermissible form of gift, entertainment or hospitality has been accepted, you must appropriately record the transaction within the register and contact the Compliance Manager immediately.

C- Facilitation payments

In many countries, it is customary business practice to make payments or gifts of small value to junior government officials in order to speed up or facilitate a routine action or process.

Although such payments are unlikely to arise given the nature of our business, we take the view that such facilitation payments are against this Contis policy and take the view that they are illegal within the UK as well as within those countries in which we operate. In particular, the UK Bribery Act 2010 makes no distinction between facilitation payments and bribes – regardless of size or local cultural expectations and even if that is “how business is done here”.

If you are unsure whether certain payments which resemble the definition of facilitation payments are permissible, please contact the Compliance Manager.

7-Local adaptation

In order for this policy to be effective, it is necessary for it to be applied across the Group worldwide, taking into consideration the diverse cultural environments in which we operate. This may require each business unit to adapt certain sections of this policy – such as gifts, entertainment and hospitality – to ensure they are fair, appropriate and applicable. Business Unit managers are responsible for reporting and confirming any local adaptations to this global policy with the Compliance Manager.

8-How to raise a concern

As individuals who work on behalf of Contis, we all have a responsibility to help protect, prevent and report instances not only of bribery, but also of any other suspicious activity or wrongdoing. Contis is absolutely committed to ensuring that all of us have a safe, reliable and confidential way of reporting any suspicious activity. We want each and everyone to know how they can “speak up”.

If you have a concern regarding a suspected instance of bribery or corruption, please speak up – your information and assistance can only help. The sooner you act, the better for you and for the Company.

If you are concerned that a corrupt act of some kind is being considered or carried out – either within Contis, by any of our business partners or by any of our competitors – you must report the issue/concern to the Manager for your business unit in Contis or the Compliance Manager or the Finance & Commercial Director or the Managing Director.

In the event that an incident of bribery, corruption, or wrongdoing is reported, we will act as soon as possible to evaluate the situation.

9-Conclusion

It is the ultimate responsibility of the main board of Contis Group to refresh and reinforce this policy and its underlying principles and guidelines. Business Unit Managers, under the overview of the Compliance Manager, are responsible for the establishment and ongoing monitoring of compliance with sections 5, 6 and 7 of this policy.

Any changes we make to our policy will be put on the website. Please check for updates from time to time.

Where you give your information on our website, we will generally only keep your information for as long as is reasonably required for the purpose(s) for which it was submitted. However, on occasion we may retain it as long as you continue to use our services. We may retain your information for an additional period as is permitted or required under applicable laws. Please note that even if we delete your data it may persist on backup or archival media for an additional period of time.

If you have any questions about this privacy policy, please contact us by using the ‘Contact us’ facility on the website or by writing to:
Data Protection Officer
Contis Financial Services
Navigation House
Belmont Wharf
Skipton
North Yorkshire
BD23 1RL

Contis Financial Services Ltd is authorised by the Financial Conduct Authority to issue eMoney (Firm Reference Number: 900025) and is a Principal Member of Visa Europe.