- Conflict Minerals Policy
- Data Protection - GDPR Policy
- Equal Opportunities Policy
- Anti-Slavery Policy Statement
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.
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.
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.
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
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
- 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 – firstname.lastname@example.org
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.
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.
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.
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