This privacy policy applies to customers of Kensa Contracting, Kensa Heat Pumps and Kensa Utilities, which are part of the Kensa Group of companies (collectively referred to as "Kensa", "we" or "us" in this policy).

This site is operated by Kensa Contracting, Kensa House, Mount Wellington, Chacewater, Truro, TR4 8RJ registered in England and Wales under company number 08166502.

Kensa Heat Pumps is registered in England and Wales under company number 03739805.

Kensa Utilities is registered in England and Wales under company number 10044238.

The Kensa Group Limited is registered in England and Wales under company number 05367753.

For the purposes of data protection legislation we are the data controller for your personal data. Kensa are registered with the Information Commissioner’s Office in the UK with reference numbers:

- Kensa Contracting: ZA163929

- Kensa Heat Pumps: ZA163920

- Kensa Group: ZA163932

‘Personal information’ means any information relating to an individual, which can identify them – either directly or indirectly. It can refer, amongst other things, to an identification number, or to one or more specific identifying pieces of information, such as an address or date of birth.

When you do any of these:

• Request an estimate;
• Request a quote;
• Place an order;
• Sign up for our newsletter;
• Fill out any forms on the Kensa website;
• Correspond with us, whether by phone, email or chat facility;
• When you browse our website.

Then, we may collect your personal information, including:

• Name;
• Company details: Business name, job title, qualification and accreditation details;
• Contact details: postal address including billing and delivery addresses, telephone numbers (including mobile numbers) and e-mail address;
• Property details relevant to your enquiry and installation i.e. build type;
• Purchases and orders made by you and quotes and estimates requested;
• When you make a purchase or place an order with us, your payment card details for the processing of the payment (details then disposed of);
• Your communication and marketing preferences;
• Your feedback and survey responses;
• Your correspondence and communications with Kensa; and
• Technical information about how you access and use our websites, including your IP address browser type and operating system. For further information about the use of your IP address and technical information please see our cookies policy.

This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Policy.

General

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

• To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us, including the provision of an estimate and quote, and fulfilment of an order and after-sales support;
• To provide you with advice and information about other goods and services we offer that are similar to those that you have already purchased or enquired about which we think may interest you;
• To ensure that content from our site is presented in the most effective manner for you and for your computer;
• Internal record keeping; and
• Where we have a legal right or duty to use or disclose your information (for example in relation to applying for the Renewable Heat Incentive (RHI) or registration with the Microgeneration Certification Scheme (MCS)).

Marketing

Kensa aims to update you about news, products & services which are of interest and relevance to you as an individual or business with regards to Kensa ground source heat pumps.

If you have requested an estimate, quote or ordered with us, or if you have expressed a commercial interest or Kensa has identified a mutual interest, Kensa may send you emails and / or postal marketing on the basis of legitimate interest, which may contain relevant advice, news and case studies to assist with your installation to ensure you make the most of your ground source heat pump, or assist with your selection of a ground source heat pump in instances where Kensa has identified you would be looking for a heating system.

You have the right to opt out of receiving postal marketing communications at any time, by:

1. Making use of the simple “opt-out” form here; and/or
2. Contacting Kensa via the contact channels set out in this Policy.

If you have opted in to receive our newsletter, Kensa will send you monthly emails containing relevant advice, news and case studies with regards to ground source heat pumps.

You have the right to opt out of receiving marketing email communications at any time, by:

1. Making use of the simple “unsubscribe” link in emails; and/or
2. Contacting Kensa via the contact channels set out in this Policy.

General

Kensa collects and uses customers’ personal data because is it necessary for:

• The pursuit of our legitimate interests (as set out below);
• The purposes of complying with our duties and exercising our rights under a contract for the sale of goods and services to a customer; or
• Complying with our legal obligations.

In general, we only rely on consent as a legal basis for processing in relation to sending direct marketing communications to non-customers via email. These individuals have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.

Our legitimate interests

The legitimate interests that we will rely upon to process your personal data include:

• Promotion of Kensa products, services and advice related to similar ground source heat pump applications to your own;
• Protecting customers, employees and other individuals and maintaining their safety, health and welfare;
• To improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• Complying with our legal and regulatory obligations;
  - preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;
  - handling customer contacts, queries, complaints or disputes;
  - protecting Kensa, its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to Kensa;
  - effectively handling any legal claims or regulatory enforcement actions taken against Kensa; and
  - fulfilling our duties to our customers, colleagues, shareholders and other stakeholders.

Our service providers and suppliers

Kensa has the right to share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

In order to make certain services available to you and to deliver our contractual obligations to you, we may need to share your personal data with some of our trusted service partners.

These include IT, delivery, installation and surveying service providers, namely Kensa approved partner installers, heat loss consultants and ground work contractors.

These service providers may use servers located in secure data centres around the world, and personal data may be stored in any one of them.

Kensa only allows its service providers to handle your personal data when we have confirmed that they apply appropriate data protection and security controls. We also impose contractual obligations on service providers relating to data protection and security, which mean they can only use your data to provide services to Kensa and to you, and for no other purposes.

Examples of service providers and their use of data are included below:

• Data for marketing emails will be processed by MailChimp. This includes the collection (via sign-up forms) and storage of personal data within Kensa’s MailChimp account in order to allow Kensa to create and use distribution lists and send marketing email campaigns, and the transfer of personal data to certain MailChimp sub-processors for some critical services e.g. abuse prevention. Data in Kensa’s MailChimp account will be removed if no history of interaction within 12 months. You can read MailChimp’s Data Processing Agreement here.
• Data input via Kensa’s website quote form is processed by Wufoo. This includes the collection and storage of personal data within Kensa’s Wufoo account in order to allow Kensa to collate information to produce an estimate and quote. Data in Kensa’s Wufoo account will be deleted after 12 months. You can read Wufoo’s Privacy Policy here.

Other third parties

Aside from our service providers, Kensa will not disclose your personal data to any third party, except as set out below. We will never sell or rent our customer data to other organisations for marketing purposes.

We may share your data with:

• Accreditation bodies for product and installation compliance with MCS and RHI requirements;
• Credit reference agencies where necessary for card payments;
• Governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so:
  - to comply with our legal obligations;
  - to exercise our legal rights (for example in court cases);
  - for the prevention, detection, investigation of crime or prosecution of offenders; and
  - for the protection of our employees and customers.

Links to other websites

Our website may contain links to other websites of interest. If you follow a link to any of these websites, please note that they have their own privacy policies and that we don’t accept any responsibility or liability for these policies. Please check these websites’ privacy policies before you submit any personal information to them.

We will not retain your data for longer than necessary for the purposes set out in this Policy.
Different retention periods apply for different types of data:
- for the purposes of MCS compliance we are required to keep data pertaining to estimates, quotes and orders for 6 years;
- we will keep data pertaining to orders for 20 years (the expected lifetime of the ground source heat pump installation) to enable responses in the event of a system failure or installation query.

Kensa is committed to keeping your personal data safe and secure.

Our security measures include:

• Kensa’s website is HTTPS with encrypted connection. We also protect the security of your data during transmission using Secure Sockets Layer (SSL) encryption software;
• Kensa’s website quote form, provided by Wufoo, is SSL encrypted;
• Security controls which protect the entire Kensa IT infrastructure from external attack and unauthorised access; and
• Internal policies setting out our data security approach and training for employees.

You may choose to restrict the collection or use of your personal information in the following ways:
- the right to ask what personal data that we hold about you at any time, subject to a fee specified by law;
- the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you free of charge; and
- (as set out above) the right to opt out of any marketing communications that we may send you.

You have the right to lodge a complaint with the Information Commissioner’s Office. Further information, including contact details, is available at https://ico.org.uk.

Kensa’s website uses applications which use cookies to collect information about browsing behaviour:

• Google Analytics: A web analysis tool provided by Google Inc. (‘Google’). Google Analytics uses cookies to track your use of the website. This information (including your IP address) is sent to Google’s servers in the USA where it’s used to prepare analysis and reports for us on the use and effectiveness of our websites. Google will not associate your IP address with any other data held by them. Visit Google Support to learn more about Google Analytics, including browser tools to prevent this tracking.
• Wordfence: A security plugin that prevents site abuse and ensures its security. Wordfence logs IP, location and computer details to identify and block spam site activity.

If you have any questions about how Kensa uses your personal data that are not answered here, or if you want to exercise your rights regarding your personal data, please contact us by any of the following means:

• Phone us on: 0345 222 4328;
• E-mail us at: info@thekensagroup.com; or
• Write to us at: Kensa Contracting Limited, Kensa House, Mount Wellington, Chacewater, Truro, TR4 8RJ

Employers Liability - Aviva Insurance Limited - GBP10,000,000 any one occurrence or series of occurrences arising out of the same cause.

Public Liability & Products Liability - Aviva Insurance Limited - GBP5,000,000 any one occurrence & in the aggregate for Products Liability

Public Liability & Products Liability- Increasing Limit to GBP15,000,000 - QBE UK Limited - GBP10,000,000

Contract Works - Aviva Insurance Limited - GBP3,500,000

Professional Indemnity - Tokio Marine HCC is a trading name of HCC International Insurance Company Plc - GBP10,000,000 any one claim

If at any time a dispute arises between you and us that cannot be resolved through our own customer service efforts, both you and we can refer the matter to be handled through RECC’s complaints procedure. We must agree to follow this procedure if that is your wish. RECC is certified through the Chartered Trading Standards Institute as an Alternative Dispute Resolution provider. You can find further information about this service on the RECC website www.recc.org.uk/consumers/how-to-complain

Initially the complaint will be allocated to a RECC caseworker, who will mediate between both parties in order to resolve the dispute. Mediation aims to reach a non-legal solution to the dispute in a reasonable timescale. If the mediator recommendations are not acceptable for any reason, you can refer the matter to RECC’s independent arbitration service and we must agree to arbitration if that is your wish. You will have to pay a fee directly to the arbitration company but this may be refunded to you if the arbitrator finds in your favour. You can find more information on the RECC website www.recc.org.uk/consumers/independent-arbitration

The outcome of the arbitration process will be legally-binding and enforceable. An award made under the independent arbitration service will be final and binding on you and us. You and we may only challenge the award on certain limited grounds under the Arbitration Act 1996.

The purpose of this policy is to support the company’s aim of providing a working environment that is free from all forms of discrimination and where all employees are treated with dignity and respect. The policy applies to all employees and other workers within the company, and unless otherwise stated, all references to employees include potential employees, former employees, full-time and part-time employees as well as agency workers, temporary workers and contractors. This policy does not form part of a workers terms and conditions of employment.

We are totally committed to the principle of equal opportunities and to creating a working environment in which employees are treated with dignity and respect that is free from unlawful discrimination, victimisation or harassment on the grounds of:

• • Colour, race, nationality, national or ethnic origin.
  • Sex, marital or civil partner status or gender reassignment.
  • Physical or mental disability of any kind.
  • Religion or belief.
  • Sexual orientation.
  • Pregnancy or maternity.
  • HIV status.
  • Age.

In this policy the above are referred to as ‘protected characteristics’.

As far as is reasonably practicable we aim to ensure that all working practices are applied fairly and consistently. Where necessary we will take reasonable steps to avoid or overcome any particular disadvantage these may cause and to promote equality. Our commitment applies to all aspects of employment including:

• • Selection for vacancies.
  • Terms and conditions of employment.
  • Training, career development and progression.
  • Relationships between members of staff.

We also respect an employee’s right to be a member or non-member of a Trade Union. This factor will not play any part in selection decisions or result in any detrimental treatment.

A breach of this policy is considered to be misconduct and disciplinary action, including dismissal for serious offences, will be taken against people who do not comply with it.

What is discrimination?

Broadly, a person has been discriminated against if:

• They have been treated less favourably than another person because of a protected characteristic or a perception that they have a protected characteristic*; or
• They have been treated less favourably than another person because of an association with someone who has a protected characteristic (e.g. their spouse or partner, a relative or child)*; or
• A procedure or practice places Employees who share a protected characteristic at a disadvantage and is not justifiable for legitimate business reasons, or through a less discriminatory alternative; or
• They have a disability (whether this is physical or mental) and reasonable steps have not been taken to meet their needs; or
• They have a disability (whether this is physical or mental) and are treated less favourably than another person because of something that is the result or effect of that disability (unless the treatment is a proportionate means of achieving a legitimate aim).

* does not apply to marital status or civil partnership

What is harassment?

Harassment is unwanted conduct which violates a person's dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment for that person. It includes physical and verbal conduct and it can also be conduct of a non-verbal nature such as sending abusive e-mails, displaying offensive posters on the wall or uploading messages or photos onto websites. Harassment may be a single incident or persistent behaviour.

Harassment is unlawful where it is motivated by one of the grounds set out above but the company includes more general harassment within its definition. Although not exhaustive, the following are examples of types of behaviour that may amount to harassment:

• Physical violence, actual or threatened.
• Physical or verbal abuse.
• Threats.
• Suggestive comments or gestures.
• Offensive or intimidating gestures, language, gossip or jokes.
• Insulting or abusive behaviour or comments.
• Isolation or exclusion such as ‘sending someone to Coventry’.
• Spreading malicious rumours.
• Unreasonable persistent criticism or humiliation.
• Unfair allocation of work or responsibilities.
• Misuse of power or position.

Bullying

Behaviour which is counted as harassment in equality law may not cover all types of behaviour which are unacceptable in the workplace. Complaints about bullying, which may not amount to harassment in equality law, may be made through the procedure described in this policy.

What is sexual harassment?

Sexual harassment is one form of harassment. Generally it involves behaviour towards another, where the perpetrator knows or should know that the behaviour is unwelcome because it is offensive and is perceived to be of a sexual nature.

Although not exhaustive, the following are examples of types of behaviour that may amount to sexual harassment:

• Physical conduct of a sexual nature - unwanted physical conduct, including unnecessary touching, brushing against another employee's body.
• Verbal conduct of a sexual nature - unwelcome sexual advances, continued suggestions of social activity outside work after it has been made clear that this is unwelcome.
• Non-verbal conduct of a sexual nature - the display of sexually suggestive or pornographic pictures or the sending of sexually harassing messages or images through electronic mail, the internet or mobile phone.
• Sex-biased conduct - Conduct that denigrates, ridicules, is intimidatory or physically abusive of an employee because of their sex, marital status or sexual orientation.

Sexual harassment by someone of the same gender as the victim also amounts to harassment.

What is third party harassment?

This is when someone, who does not work for Kensa, harasses an employee. For example, a customer acts abusively towards an employee. We are committed to taking all reasonable steps to prevent this form of harassment. If an employee is harassed in this way they should report it to their Line Manager.

What is victimisation?

Someone is victimised where they suffer unfavourable treatment because they have, in good faith, made a complaint under this policy, acted as a witness or accompanied a complainant at a meeting.

Working with the company

It is our staff’s obligation to be sensitive about the impact that they have on others and behave in a way that supports the policy. The policy is not designed to discourage normal social relations among colleagues or with the public but aims to prevent discrimination, harassment and victimisation.

Our policy applies not only at the company’s premises but anywhere staff are working as part of their employment with the company. This includes any social occasions organised by the company.

Staff must not instruct or aid someone to carry out an act of discrimination, harassment or victimisation or condone discrimination, harassment or victimisation by others. Staff have a responsibility to promptly report any such behaviour of which they become aware.

As a manager

In addition to employees’ general responsibilities above, it is also their responsibility to apply this policy as part of day to day management within the company and to make sure that their team are aware of and comply with this policy.

All workers should note that they may be held personally liable for some acts of harassment that they commit, encourage others to commit or do not deal with, prevent or report once aware of them. This can lead to an employee being required to pay compensation to a victim of harassment.

The company encourages employees who have a complaint to raise this as promptly as possible as this is more likely to enable the facts to be established accurately and a successful resolution to be achieved. The company aims to deal with all complaints as quickly as possible. The company will take all complaints seriously and no employee who makes a complaint in good faith, or participates in an investigation or a complaint will be victimised for doing so.

The company treats all complaints as confidential but it may be necessary to disclose certain information to other personnel during disciplinary action. We will seek to act in accordance with the wishes of complainants and witnesses concerning their identity but cannot guarantee anonymity.

The company will take a view on whether behaviour complained of amounts to harassment considering both the effect on the complainant and whether the behaviour would reasonably be expected to have caused such an effect. This means that harassment may have taken place even if there was no intention to cause offence. It is also possible that an individual may find behaviour objectionable that the company views as reasonable or legitimate

Complaints that are not made in good faith and involve deliberate misuse of the above procedure may result in disciplinary action being taken against the complainant.

Informal Stage

The employee should consider whether it is appropriate to raise the matter directly with the person concerned in order to resolve the problem. If it is not, the employee should speak to their manager or if they feel unable to discuss the matter with their manager then they should discuss it with a Director of the company.

Following the discussion, the employee will be asked to choose one of the following options:

• agree that no further action is necessary;
• agree to discuss the complaint with the individual who is alleged to have caused offence to ask them to stop;
• put their complaint in writing to the person causing the problem;
• ask a friend or colleague to speak to the person on their behalf;
• ask their manager / Director to help to resolve the matter through informal and/or discreet approaches; or

Raise a grievance about their concerns. If they are not satisfied with an informal approach, a grievance can be initialised at any stage.

Formal Stage

If an employee prefers, they may use a more formal approach to resolving the problem by raising a grievance at Stage 1 of that policy. The formal procedure may be more appropriate in instances of serious complaint or where an attempt at informal resolution has not been successful. It is up to the employee to decide the best approach. Please be aware, however, that the company has a duty to protect all its workers and may be obliged to pursue a complaint independently, if considered necessary and appropriate in all the circumstances.

The normal provisions of the grievance policy apply to a complaint regarding discrimination, harassment or victimisation including the right to be accompanied at a grievance meeting and to appeal the Stage 1 outcome. The employee’s written grievance should be signed and dated and include full details of the behaviour, the identity of the alleged harasser, any documentary evidence, details of witnesses and any action that has been taken to date.

Following receipt of the employee’s grievance, the allegations will be investigated as carefully and discreetly as possible. This will involve hearing detailed accounts from all parties. Other members of staff may also be asked to provide information. Documents, e-mail and other evidence may be considered.

Where a formal investigation has been conducted and where it has been reasonably concluded that some form of discrimination, harassment or victimisation may have taken place, those responsible will be subject to our normal disciplinary policy. Action will not normally be initiated without the agreement of the complainant but there are some circumstances where the company may need to pursue the matter formally. For example, if other people could be at risk if no action is taken.

The outcome of any disciplinary procedure will depend upon the circumstances. Consideration may be given to redeploying either the discriminator/harasser or the complainant if this is practicable. If redeployment is considered, the wishes of the complainant will be taken into account and the complainant will not usually be redeployed if they do not want to be.

Special requirements relating to Equal Opportunities

The company understands that people's needs at work are different and that some employees may have special requirements. For example, employees of a particular religion may need somewhere quiet to pray during their lunch break, need to take holiday on a particular day for a religious event, or need to have somewhere to store specially prepared foods. An employee may have a disability and may feel that they need to have changes made to their workplace to help them do their job. Employees should speak to their manager if this is the case.

The company will accommodate employee’s requirements where it is possible and practical. Where an employee needs particular time off, or are requesting a temporary change to working hours, their manager is more likely to be able to accommodate this if they have been told well in advance.

Recruitment & Selection

The recruitment and selection process will be free from bias or discrimination. Recruitment will be managed objectively and decisions about suitability for vacancies will be based on specific and reasonable job criteria. The company is positively committed to making reasonable adjustments for those who have a disability in the recruitment and selection process, or to enable someone to work with the firm.

Employment Conditions

Terms and conditions of employment, including pay and benefits, will be offered to employees fairly and consistently. Part-time employees will be provided with comparable employment conditions on a pro-rata basis to full-time employees unless different treatment is objectively justifiable.

In this policy “we”, 'us”, and “the Company” mean Kensa Contracting Ltd.

“Bribe” means an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage; “to Bribe” and “Bribery” are construed accordingly.

“Relevant Person” means any individual (whether an officer of employee of the Company, or a

temporary worker, contractor or consultant providing services to or on behalf of the Company) or any corporate entity who performs functions for or on behalf of the Company.

1. Introduction

One of Kensa Contracting core values is to uphold responsible and fair business practice. It is committed to promoting and maintaining the highest level of ethical standards in relation to all of its business activities. Its reputation for maintaining lawful business practices is of paramount importance and this Policy is designed to preserve these values. Kensa Contracting Ltd therefore has a zero tolerance policy towards bribery and corruption and is committed to acting fairly and with integrity    in all of its business dealings and relationships and to implementing and enforcing effective systems to counter bribery.

1. Purpose and scope of this policy

This Policy sets out the steps all of us must take to prevent bribery and corruption in our business and to comply with relevant legislation. It is aimed at:

• ensuring compliance with anti-bribery laws, rules and regulations, not just within the UK but in any other country within which Kensa Contracting Ltd may carry out its business or in relation to which its business may be connected;

• enabling any Relevant Person to understand the risks associated with bribery and to encourage them to be vigilant and effectively recognise, prevent and report any wrongdoing, whether by themselves or others;

• providing suitable and secure reporting and communication channels and ensuring that any information that is reported is properly and effectively dealt with;

• creating and maintaining a rigorous and effective framework for dealing with any suspected instances of bribery or corruption. 
All Relevant Persons are expected to adhere to the principles set out in this

1. The Bribery Act 2010

The Bribery Act 2010 (the Bribery Act) came into force on 1 July 2011. The Bribery Act affects Kensa Contracting Ltd  in its business relations anywhere in the world.

Under the Bribery Act it is an offence to:

1. bribe a person i.e. to offer, promise or give a financial or other advantage to another person, whether within the UK or abroad, with the intention of inducing or rewarding improper conduct;

1. receive a Bribe i.e. to request, agree to receive or accept a financial or other advantage for or in relation to improper conduct;

1. bribe a foreign public official; and

1. fail to prevent

1. Risks of not acting with integrity

Involvement in Bribery or corruption carries many risks. Among them are:

• a company which pays or accepts Bribes is not in control of its business and is at risk of blackmail;

• if Kensa Contracting Ltd is found guilty of Bribery or even of failing to have adequate procedures in

place to prevent Bribery, it will be subject to unlimited fines;

• any person found guilty of Bribery will be subject to fines and/or imprisonment of up to 10 years;

• a public exposure, or even allegation, of bribery would entail severe reputational damage. Kensa Contracting Ltd banking or supply facilities might be withdrawn or be available on much less favourable terms, and Kensa Contracting Ltd could be blacklisted as an approved tenderer for both public and private sector contracts;

• the cost of our insurance cover could increase very significantly; and good people will not want to work for

1. Benefits of acting with integrity

Equally, there are very clear benefits to acting with propriety. These include:

• we increase our chances of being selected as a supplier in both the public and private sectors;

• we remain in good standing with our banks and our own suppliers and they will want to keep doing business with us;

• a business with high ethical standards is a good place to work

1. Policy statement

All Relevant Persons and Associated Persons are required at all times:

• not to commit an offence listed above at section 4 or any other offence;

• to comply with the Bribery Act

• to act honestly, responsibly and with integrity;

• to safeguard and uphold Kensa Contracting Ltd’s core values by operating in an ethical, professional and lawful manner at all times. 
Bribery of any kind is strictly prohibited. Under no circumstances should any provision be made, money set aside or accounts created for the purposes of facilitating the payment or receipt of a Bribe. 
All Relevant Persons and all Associated Persons are expected to adhere strictly at all times to the guidelines set  out  in  this Policy. If you are in doubt as to what might amount to bribery or what might constitute a breach of this Policy, refer the matter to your line

1. Gifts and Hospitality

This Policy covers the offer or receipt of gifts, hospitality or expenses to ensure that any legitimate expenditure is recorded and does not improperly affect the outcome of procurement, application or any other business transaction.

1. Kensa Contracting Ltd forbids any Relevant Person from soliciting any gift or hospitality in the course of his/her employment or engagement with Kensa Contracting Ltd or, if a corporate entity, for the duration of any contract between that corporate entity and Kensa Contracting Ltd

1. Kensa Contracting Ltd forbids any Relevant Person from offering or receiving from any person or organization who has had, has or may have any influence over the business Kensa Contracting Ltd :

.                    (a).  a personal or corporate gift to a value in excess of £10;

.                    (b).  hospitality to a value in excess of £75

1. Kensa Contracting Ltd forbids any officer, employee, temporary worker or contractor of Kensa Contracting Ltd from offering or receiving any gift or hospitality which is in breach of relevant

1. Kensa Contracting Ltd forbids any Relevant Person either directly or indirectly from making an offer of, or making a donation to any political, charitable or not for profit organisation in the course of his/her employment or engagement with Kensa Contracting Ltd or, if a corporate entity, for the duration of any contract between that corporate entity and Kensa Contracting Ltd , as a way to obtain an advantage in a business

1. Kensa Contracting Ltd may exercise its discretion to permit gifts or hospitality which exceeds the threshold limits in paragraph

1. All Relevant Persons must enter details of all gifts and hospitality made or received which are permitted by paragraphs 2, 4 and 5, onto the Central Register of Gifts. The Central Register of Gifts is reviewed and monitored by Kensa Contracting Ltd and the management of Kensa Contracting Ltd and will be

1. Facilitation payments

Any payment or gift to a public official or other person to secure or accelerate the prompt or proper performance of a routine government procedure or process, otherwise known as a “facilitation payment”, is also strictly prohibited. Facilitation payments are not commonly paid in the UK but they are common in some other jurisdictions.

1. What are the indicators of bribery?

Common indicators of corruption include those listed below. There may well be others. For example:

• payments are for abnormal amounts (e.g. commission), or made in an unusual way, eg what would normally be a single payments is made in stages, through a bank account never previously used, or in a currency or via a country which has no connection with the transaction;

• process is bypassed for approval or sign-off of terms or submission of tender documents, payments, or other commercial matters; those whose job it is to monitor commercial processes may be prevented from or hindered in doing so;

• individuals are secretive about certain matters or relationships and/or insist on dealing with them personally. They may make trips at short notice without explanation, or have a more lavish lifestyle than expected;

• decisions are taken for which there is no clear rationale;

• records are incomplete or

1. Political contributions

You should be aware that such contributions can be (or be seen as) Bribes in disguise. We do not make donations to political parties. No individual is to make a donation stated to be, or which could be taken to be, on our behalf without the prior approval of Kensa Contracting Ltd . You may, of course, make political donations in a personal capacity but please be sensitive to how such contributions could be perceived, especially by those who are aware of your connection with Kensa Contracting Ltd .

1. Charitable donations

Bribes may even be disguised as charitable donations. Again, for that reason, donations we make are approved by resolution of Kensa Contracting Ltd  and recorded. Whilst individuals may of course make personal donations to charity, they should not do so on behalf of Kensa Contracting Ltd without prior approval from Kensa Contracting Ltd .

1. Local circumstances

We understand that different parts of the world have different social and cultural customs. This does not affect our position that we do not pay or accept bribes or act corruptly: we do not and will not. However, subject to that position, we understand the need to be sensitive to local customs. For example, there are cultures in which refusing (or even failing to offer) a gift is considered impolite, and could alienate a key contact. In such cases, please refer to the Managing Director.

1. Exceptional circumstances

In some circumstances a payment is justifiable. If one of our people is faced with a threat to his or her personal safety or that of another person if a payment is not made, they should pay it without fear of recrimination. In such cases, however, Kensa Contracting Ltd must be contacted as soon as possible, and the payment and the circumstances in which it was made must be fully documented and reported to all relevant managers within 5 working days.

Such cases will be rare. All Relevant Persons visiting regions where they are more common should familiarise themselves, prior to travel, with current guidance relating to those countries. For general information on travelling to a particular country, please consult the latest information from the Foreign and Commonwealth Office.

1. Responsibility to report and the reporting procedure

All Relevant Persons are contractually required to take whatever reasonable steps are necessary to ensure compliance with this Policy and to prevent, detect and report any suspected Bribery or corruption. All Relevant Persons have a duty to prevent, detect and report any incident of Bribery and any potential risks of Bribery. If you know or suspect that any Relevant Person plans to offer, promise or give a Bribe or to request, agree to receive or accept a Bribe in connection with Kensa Contracting Ltd - business, you must disclose this to your line manager as quickly as possible to allow appropriate action to be taken promptly.

Kensa Contracting Ltd is committed to taking appropriate action against Bribery and corruption. This may include either reporting the matter to an appropriate external government department, regulatory agency or the police and/or taking internal disciplinary action against relevant employees and/or terminating contracts with associated persons.

Kensa Contracting Ltd will keep your disclosure confidential during any investigation it undertakes to the extent that this is practical and appropriate in the circumstances. Kensa Contracting Ltd will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken Kensa Contracting Ltd is also committed to ensuring nobody suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or corruption offence has taken place or may take place in the future or because they may assist in the investigation of an allegation of Bribery or corruption.

1. Record keeping

All accounts, receipts, invoices and other documents and records relating to dealings with third parties must be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off the record” to facilitate or conceal improper payments.

1. Monitoring compliance

the Managing Director  has primary responsibility for ensuring compliance with this Policy.

1. Sanctions for breach of this Policy

A breach of any of the provisions of this Policy by any Relevant Person who is an officer or employee of Kensa Contracting Ltd will constitute a disciplinary offence and will be dealt with in accordance with Kensa Contracting Ltd disciplinary procedure. Depending on the gravity of the offence, it may be treated  as  gross  misconduct  and  could  render  the  officer  or  employee  liable  to  summary dismissal.

Breach of this policy by any Relevant Person who is a temporary worker, contractor or consultant providing his/ her services to Kensa Contracting Ltd may lead to the immediate termination of that temporary worker’s, contractor’s or consultant’s engagement by Kensa Contracting Ltd.

Breach of this policy by any Relevant Person which is a corporate entity could lead to the suspension or termination of any relevant contract, sub-contract or other agreement between the corporate entity and Kensa Contracting Ltd.

The term ‘Kensa Contracting’ or ‘us’ or ‘we’ refers to the owner of the website whose registered office is Kensa Contracting Limited, Kensa House, Mount Wellington, Chacewater, Truro, TR4 8RJ.

Our company registration number is 08166502. Registered in England.

The term ‘you’ refers to the user or viewer of our website.

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

• The content of the pages of this website is for your general information and use only. It is subject to change without notice.
• We do not provide any warranty or guarantee as to the accuracy, timeliness, performance, completeness or suitability of the information and materials found or offered on this website for any particular purpose. You acknowledge that such information and materials may contain inaccuracies or errors and we expressly exclude liability for any such inaccuracies or errors to the fullest extent permitted by law.
• Your use of any information or materials on this website is entirely at your own risk, for which we shall not be liable. It shall be your own responsibility to ensure that any products, services or information available through this website meet your specific requirements.
• This website contains material which is owned by or licensed to us. This material includes, but is not limited to, the design, layout, look, appearance and graphics. Reproduction is prohibited other than in accordance with the copyright notice, which forms part of these terms and conditions.
• All trade marks reproduced in this website which are not the property of, or licensed to, the operator are acknowledged on the website.
• Unauthorised use of this website may give rise to a claim for damages and/or be a criminal offence.
• From time to time this website may also include links to other websites. These links are provided for your convenience to provide further information. They do not signify that we endorse the website(s). We have no responsibility for the content of the linked website(s).
• Your use of this website and any dispute arising out of such use of the website is subject to the laws of England, Northern Ireland, Scotland and Wales.

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

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

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

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

This website and its content is copyright of Kensa Contracting – © Kensa Contracting 2019. All rights reserved.

Any redistribution or reproduction of part or all of the contents in any form is prohibited other than the following:

• You may print or download to a local hard disk extracts for your personal and non-commercial use only;
• You may copy the content to individual third parties for their personal use, but only if you acknowledge the website as the source of the material.

You may not, except with our express written permission, distribute or commercially exploit the content. Nor may you transmit it or store it in any other website or other form of electronic retrieval system.