Privacy Policy

Vinco Recruitment Limited (“We” or “us” or “Vinco Recruitment”) are committed to protecting and respecting your privacy.

As a business which relies upon having access to a database of pre-qualified candidates to meet our clients' requirements, data is essential to our business. Our systems and processes are designed to ensure that we can provide the best possible service to our clients while operating within the law at all times and protecting individuals’ data privacy rights.

This notice together with our terms of business sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. You should read this Privacy Notice if you are a Candidate, Client Contact or Supplier Representative.

We reserve the right to update this Privacy Notice when we require it. Where appropriate, we shall contact you to notify you of any material changes to the Privacy Notice. You should also refer to our website periodically so that you may access and view our updated Privacy Notice. This will ensure that you understand (i) how we are using your personal data and (ii) your legal rights around our usage of such personal data.

For the purposes of data protection legislation in force from time to time the data controller is Vinco Recruitment Limited whose registered office is located at 4015 Robinson Building, Norfolk Place, Bedminster, BS3 4AE.

Our nominated representative on this is Freya Sutherland - Director

Who we are and What We Do

We are a recruitment agency and recruitment business as defined in the Employment Agencies and Employment Businesses Regulations 2003. We collect the personal data of the following types of people to allow us to undertake our business;

Prospective and placed candidates for permanent or temporary roles;
Prospective and live client contacts;
Supplier contacts to support our services;
Employees, consultants, temporary workers;

2. How We Obtain Personal Data

We obtain personal data from different sources, depending on whether you are a Candidate, a Client Contact or a Supplier Representative.

2.1. If you are a Candidate, we may obtain personal data relating to you:

2.1.1. Directly if you have:

applied for a client vacancy through us

uploaded your CV through our website
asked us to provide any work-finding services to you
engaged with us through any networking activities or events
had any discussions with us about finding alternative employment

2.1.2. Indirectly from:

online professional networking sites such as LinkedIn
social networking sites such as, but not limited to X (Twitter)
job boards such as, but not limited to Total Jobs, CV Library or Reed
referees who provide information about your employment experience and their opinion as to your skills and aptitude

your employer’s website and other industry-related websites
business information directories
online industry databases such as Industry Training Board
where appropriate, third-party background checking services such as the Disclosure & Barring Service

2.2. If you are a Client Contact or Supplier Representative, we may obtain personal data relating to you:

2.2.1. Directly in the course of (i) us providing services to you or (ii) you providing services to us, as applicable; or

2.2.2. Indirectly from:

online professional networking sites such as LinkedIn
your employer’s website and other industry-related websites

business information directories
other individuals within your organisation in the course of (i) us providing services to you or (ii) you providing services to us, as applicable.

3. Types of Information We Hold

3.1. If you are a Candidate, we may collect, store and process the following types of personal information about you:

Personal contact details such as name, title, addresses, telephone numbers, and email addresses;
Your gender, date of birth, nationality and place of residence;
Your professional skills and experience;

Your qualifications, training and certifications;
Proof of your right to work in the United Kingdom such as copies of your passport and, where applicable, visa, residence permit or similar government documents;
Proof of your identity and address, such as copies of your driving licence, utility bills or similar documents;
Information about your current or most recent role, including your job title, department, reporting line, responsibilities, salary, benefits and notice period;
Your motivation and reasons for seeking new employment;

Any information within your CV or any application document which a Client may require you to complete;
Any background information which you provide to us during the course of your dealings with us;
Details of any Clients to whom you have been introduced by us;
Details of any interviews which you have attended and our Clients’ feedback on those interviews;
Details of any position which you take up with a Client, including your role, duties, remuneration, department and location;

Where you provide any services on a freelance basis:

Details of any limited company through which you contract and the nature of your relationship with that company;
Information about the days and times which you have worked;
Your bank details, tax code and National Insurance Number; and

Information about any services which you have carried out, including any comments, feedback and issues relating to such services.

We may also ask for your consent to collect, store and use the following “special categories” of more sensitive personal information:

Information about your race or ethnicity;
Information about your health, including any medical condition, health and sickness records; and

Information about criminal convictions and offences.

Should we want or need to rely on consent to lawfully process your data we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our system.

3.2. If you are a Client Contact, we may collect, store, and use the following categories of personal information about you:

Personal contact details such as name, title, addresses, telephone numbers, and email addresses;

Your job title and position within the Client organisation; and
Any background information relating to your personal circumstances, your work history and the role which you perform within the Client which you may provide to us in the course of your dealings with us.

We do not collect, store or use any “special categories” of sensitive personal information if you are a Client Contact.

3.3. If you are a Supplier Representative, we will collect, store, and use the following categories of personal information about you:

Personal contact details such as name, title, addresses, telephone numbers, and email addresses;
Your job title and position within the Supplier organisation; and
Any background information relating to the role which you perform within the Supplier which you may provide to us in the course of your dealings with us.

4. How We Use Personal Data

4.1. If you are a Candidate, we may use your personal data to:

Assess and verify your potential suitability for employment with a Client;
Contact you in relation to any potential employment opportunities with a Client;

Introduce you to our Clients and potentially arrange for you to fill a Client vacancy;
Stay in regular contact with you to understand your current position, career aspirations and motivation for finding new employment;
Where applicable, make payments to you or arrange for any third-party company through which you may contract to make payments to you;
Contact you to ask for a referral;
Produce anonymised statistical data;

Conduct satisfaction surveys;
Comply with our legal obligations, defend or bring any legal proceedings and prevent fraud or any other crime; and
Conduct equal opportunities monitoring.

4.2. If you are a Client Contact, we may use your personal data to:

Contact you to obtain information about our Client’s requirements;
Liaise with you so that we may effectively perform the services to our Client;
Obtain a reference for a Candidate;
Contact you for invoicing and credit control purposes;
Conduct satisfaction surveys;

Comply with our legal obligations, defend or bring any legal proceedings and prevent fraud or any other crime.

4.3. If you are a Supplier Representative, we may use your personal data to:

Liaise with you in respect of the services which are being provided by the Supplier;
Contact you in relation to billing matters;
Comply with our legal obligations, defend or bring any legal proceedings and prevent fraud or any other crime.

5. Our Lawful Basis for Processing Data

We have determined that we have a legitimate interest to process your personal data where you are:

5.1. A Candidate, on the basis that it is necessary for us to maintain a database of individuals who are (i) actively seeking new employment with a Client or (ii) potentially suitable for employment with a Client. By processing your personal data and contacting you from time to time, we are able to gain an understanding of your current role (where applicable), your skills and experience, and your career aspirations. Our processing of your personal data is therefore of benefit to:

You, as it assists us to identify new employment opportunities about which you might not otherwise been aware and to give general advice and guidance in support of your career development;
Our Clients, who rely on us to have access to suitable, pre-qualified candidates who can fill their requirements; and
Us, as we are a commercial enterprise which relies upon being able to introduce Candidates to our Clients

5.2. A Client Contact, on the basis that we need to be able to contact and interact with the individuals who are employed or engaged by our Clients. This will allow us to effectively provide services to them, better understand their requirements and generate revenue for our business.

5.3. A Supplier Representative, on the basis that we need to be able to contact and interact with the individuals who are employed or engaged by our Suppliers. This will allow us to ensure that our Suppliers provide us with the best possible service which, in turn, is of direct benefit to both our Candidates and our Clients.

6. Where We Process Personal Data

Your personal data is primarily held and processed by us in the United Kingdom.

We may also use commercial-grade cloud storage services such as Microsoft OneDrive and Dropbox to store personal data relating to you. These are international businesses which may securely process data anywhere in the world. They do not perform any other form of processing on our behalf and are not entitled to use any personal data which is controlled by us for any other purpose.

We have put in place appropriate safeguards to ensure that your data is only transferred to jurisdictions with enforceable data subject rights and effective legal remedies in respect of data privacy breaches. In addition, we will only transfer personal data to jurisdictions outside of the EEA where:

There are binding corporate rules in place regarding the transfer of such data within the Group, in accordance with Article 47 of the GDPR;
The European Commission has made an adequacy decision in respect of such jurisdiction;

The transfer of data is subject to the model contractual clauses adopted by the European Commission; or
You have consented to the transfer of such data.

7. Parties with Whom We May Share Data

7.1. If you are a Candidate, we may share your personal data with:

A Client where you have expressed an interest in being introduced to such Client;
Any third-party which is engaged by the Client to assist them in the recruitment process including a managed service company, Recruitment Process Outsourcing provider or IT services provider;
A third-party company through which you are contracting;

A third-party company to which you have specifically asked to be introduced or referred, such as an insurance company or intermediary (umbrella) company;
Background checking services such as the Disclosure & Barring Service;
Industry bodies such as the Construction Industry Training Board and any similar organisations which are relevant to the market sector in which you work;
Third-Party Services Providers;
Governmental departments and agencies where we are permitted or required by law to do so.

We may also share your personal data with Clients on an anonymised basis where we have agreed to provide general statistical information to such Clients.

7.2. If you are a Client Contact, we may share very limited data relating to you with a Candidate where such sharing is strictly required for the recruitment process e.g. so that the Candidate may contact you directly. We will also share your personal data with Third-Party Services Providers for legitimate business purposes.

7.3. If you are a Supplier Representative, we will share your personal data with other Third-Party Services Providers for legitimate business purposes.

8. Automated Decision Making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.

All decisions which are made during our business processes involve human intervention. We do not therefore expect to make any decisions about you using automated means, whether you are a Candidate, Client Contact or Supplier Representative.

9. Data Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from the Operations Team.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

10. Data Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Our standard data retention period is two years from the last date on which we are in actual contact with you i.e. where we actually speak with you or exchange correspondence. After this time, we will usually delete your personal data from our records.

Where we are required to keep any information (i) for auditing or compliance purposes (ii) to comply with our contractual obligations to third parties or (iii) in respect of any potential or actual legal proceedings, we shall keep your data for as long as is strictly necessary for these purposes, which is typically for six years from the date on which the relevant business activities were carried out.

In some circumstances we may completely anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

11. Our Website

If you interact with our website (www.vincorecruitment.co.uk), we may process information pertaining to such usage.

12. Rights of access, correction, erasure, and restriction

12.1. Your duty to inform us of changes. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

12.2. Your rights in connection with personal information. Under certain circumstances, you have the right to:

Request access to your personal information (a Subject Access Request). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. You will not usually have to pay a fee to access your personal information but we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed or you have objected to the processing and there is no overriding legitimate interest for continuing the processing.

Object to processing of your personal information where we are relying on a legitimate interest and you object on “grounds relating to your particular situation.”
Request the restriction of processing of your personal information. This enables you to ask us to block or suppress the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it or if you have also objected to the processing as above.
Request the transfer of your personal information to another party when the processing is based on consent and carried out by automated means. This right is not applicable to any data processing carried out by Vinco Recruitment.
If you want to exercise any of the above rights, please contact us. We will consider your request and confirm the actions which we have taken in response to such request.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Operations Team. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. We will confirm the actions which we have taken in respect of any such request.

In the EEA, you can also make a complaint to our supervisory body for data protection matters (the Information Commissioner’s Office in the UK) or seek a remedy through local courts if you believe your rights have been breached. You can find details of how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113

13. Definitions

Candidate means a person who is registered with Vinco Recruitment as seeking or potentially seeking new employment or engagement. This includes individuals who are not actively seeking a new role but who would like to remain in contact with Vinco Recruitment about potential opportunities which may be of interest from time to time.

Client means a business which has engaged Vinco Recruitment to provide services or which Vinco Recruitment has identified as a business for which it wishes to perform services.

Client Contact means a person who is employed or engaged by a Client and with whom Vinco Recruitment may liaise in respect of any services which Vinco Recruitment is providing or wishes to provide to the Client.

Data Protection Legislation means (i) unless and until the GDPR is no longer directly applicable in the UK, the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 1998.

Supplier means a business which provides services to Vinco Recruitment and which may process personal data relating to any Candidate, Client Contact or Supplier Representative in the course of performing such services.

Supplier Representative means a person who is employed or engaged by a Supplier and with whom Vinco Recruitment may liaise from time to time in respect of the services which are provided by that Supplier.

Third-Party Services Provider means any relevant third-party business which provides services to us, including:

professional advisers including accountants, tax advisors, lawyers marketing specialists, event organisers and other financial service providers;
sub-contractors in technical, professional, payment and other services;
analytics and search engine providers that assist us in the improvement and optimisation of our site;

IT services providers and software providers;
satisfaction survey distribution, collection and monitoring;
credit reference agencies, insurance brokers and compliance partners.

14. Contacting Us

If you have any questions about this Privacy Notice, you can email us;

contact@vincorecruitment.co.uk

Equal Opportunities Policy

Vinco Recruitment is committed to encouraging equality, diversity and inclusion among our workforce, and eliminating unlawful discrimination.

The aim is for our workforce to be truly representative of all sections of society and our customers, and for each employee to feel respected and able to give their best.

The organisation - in providing goods and/or services and/or facilities - is also committed against unlawful discrimination of customers or the public.

Our policy’s purpose

This policy’s purpose is to:

1. Provide equality, fairness and respect for all in our employment, whether temporary, part-time or full-time

2. Not unlawfully discriminate because of the Equality Act 2010 protected characteristics of:

age
disability
gender reassignment
marriage and civil partnership
pregnancy and maternity
race (including colour, nationality, and ethnic or national origin)
religion or belief
sex
sexual orientation

3. Oppose and avoid all forms of unlawful discrimination. This includes in:

pay and benefits
terms and conditions of employment
dealing with grievances and discipline
dismissal
redundancy
leave for parents
requests for flexible working
selection for employment, promotion, training or other developmental opportunities

Our commitments

The organisation commits to:

1. Encourage equality, diversity and inclusion in the workplace as they are good practice and make business sense.

2. Create a working environment free of bullying, harassment, victimisation and unlawful discrimination, promoting dignity and respect for all, and where individual differences and the contributions of all staff are recognised and valued.

This commitment includes training managers and all other employees about their rights and responsibilities under the equality, diversity and inclusion policy. Responsibilities include staff conducting themselves to help the organisation provide equal opportunities in employment, and prevent bullying, harassment, victimisation and unlawful discrimination.

All staff should understand they, as well as their employer, can be held liable for acts of bullying, harassment, victimisation and unlawful discrimination, in the course of their employment, against fellow employees, customers, suppliers and the public

3. Take seriously complaints of bullying, harassment, victimisation and unlawful discrimination by fellow employees, customers, suppliers, visitors, the public and any others in the course of the organisation’s work activities.

Such acts will be dealt with as misconduct under the organisation’s grievance and/or disciplinary procedures, and appropriate action will be taken. Particularly serious complaints could amount to gross misconduct and lead to dismissal without notice.

Further, sexual harassment may amount to both an employment rights matter and a criminal matter, such as in sexual assault allegations. In addition, harassment under the Protection from Harassment Act 1997 – which is not limited to circumstances where harassment relates to a protected characteristic – is a criminal offence.

4. Make opportunities for training, development and progress available to all staff, who will be helped and encouraged to develop their full potential, so their talents and resources can be fully utilised to maximise the efficiency of the organisation.

5. Make decisions concerning staff being based on merit (apart from in any necessary and limited exemptions and exceptions allowed under the Equality Act).

6. Review employment practices and procedures when necessary to ensure fairness, and also update them and the policy to take account of changes in the law.

7. Monitor the make-up of the workforce regarding information such as age, sex, ethnic background, sexual orientation, religion or belief, and disability in encouraging equality, diversity and inclusion, and in meeting the aims and commitments set out in the equality, diversity and inclusion policy.

Monitoring will also include assessing how the equality, diversity and inclusion policy, and any supporting action plan, are working in practice, reviewing them annually, and considering and taking action to address any issues.

Agreement to follow this policy

The equality, diversity and inclusion policy is fully supported by all at Vinco Recruitment.

Anti-Bribery Policy

Anti-Bribery and Corruption Policies

1. Purpose and scope

Vinco Recruitment, our employees and the third parties we engage are subject to several anti-bribery and corruption (ABC) laws in all the countries where we operate, including but not limited to the UK Bribery Act of 2010 which can apply to acts committed anywhere in the world. Violations of ABC laws are treated very seriously by enforcement authorities across the world and may result in severe criminal, civil and regulatory penalties for Vinco Recruitment and any involved individuals. Criminal penalties may include significant fine and imprisonment.

We understand that any involvement or perceived involvement in bribery or corruption could significantly damage our reputation and harm the trust we have established with our employees, clients, and the communities where we work.

We take a zero-tolerance approach to bribery and corruption so to safeguard against this our policy sets out:

The principles and requirements you must follow to avoid engagement in bribery and corruption.
Details of how to recognise bribery and corruption.
Instructions confirming out how to report any concerns relating to any actual, alleged, or suspected breach of this policy.

Vinco Recruitment (referred to in this policy as “the Company, Vinco Recruitment, us, we, our”), takes a zero-tolerance approach to bribery and corruption.

Vinco Recruitment's Directorate are fully committed to this policy and supporting your compliance with it. The Founding Directors have overall accountability for compliance with this policy and each member of the Directorate is accountable for ABC compliance in relation to their area of responsibility.

This policy applies to everyone who works for us whether on a permanent or temporary basis, anywhere in the world, including all employees, workers, agency workers, employed contractors and temporary staff (collectively, “employees” or “you”) unless otherwise specified.

All individuals, groups of individuals and entities working on our behalf or providing services to Vinco Recruitment will be held to the same ethical standard as our employees, This policy is non-contractual and may be amended by us from time to time without notice to the employee so please check back regularly to obtain the latest copy of this Policy.

2. Key definitions

Bribery involves the offering, giving, requesting, or receiving of money, anything of value or anything else that may be considered a bribe, as an inducement or reward for an improper act or to influence someone in the performance of their role. For purposes of assessing a bribery risk, “an improper act” generally refers to someone performing (or failing to perform) a function or activity in a manner that is illegal, unethical, in bad faith or in breach of a position of trust. Bribes are sometimes called “kickbacks”. “Anything else of value” includes, but is not limited to the following:

Gifts (including cash equivalents, such as gift cards or vouchers)
Favourable commercial arrangements (e.g. favourable contracts)
Hospitality, such as meals, hotel stays, tickets or invitations to sporting or cultural events
Other promotional expenses (such as travel and accommodation expenses)
Favours that are of value to the recipient (such as offers of employment, work experience or
internships for a directly involved party or a relative of a party)
Free use of company services, facilities or property
Political contributions
Charitable Donations

Charitable Donations means voluntary philanthropic contributions and non-commercial sponsorship in the form of monetary or non- monetary Gifts, for which no return payment or service is expected or made.

Corruption refers to the misuse of public office or power for private gain, or the misuse of private power in relation to business. Corruption can take many forms, such as fraud, extortion, Bribery or Facilitation Payments.

Facilitation Payments, sometimes called “grease payments”, are unofficial payments or gifts made to secure, facilitate or speed up a Public Official’s performance of a government action or process. These government actions or processes include, but are not limited to, issuing licenses or permits and scheduling inspections.

Gifts means all products, services, cash or cash equivalents (such as cheques, prepaid debit or credit cards, gift cards, vouchers, loans and shares) and all business courtesies, gratuities, discounts, favours and other things of any value (even if nominal) for which the recipient does not pay the fair value.

Hospitality means all meals, drinks, entertainment (including, but not limited to, tickets or invitations to sporting or cultural events), recreation, travel, accommodation (such as hotel stays) and other courtesies which are of any value (even if nominal) and for which the recipient does not pay the fair value.

Political Contributions includes (but is not limited to) gifts (of money or other property), sponsorship, subscription or membership fees, of any political party, candidate or political party/action committee and donations to charities that have political affiliations or connections.

Public Officials Includes (but is not limited to):

Individuals (whether elected or appointed) who hold positions of any kind (such as legislative, administrative, military or judicial) in any national, local or municipal government.
Individuals who exercise a public function for or on behalf of any branch or public agency of any national, local or municipal government officers, employees or representatives of any government/state-owned or controlled commercial enterprise (“SOE”), public international organisation, non-governmental organisation or of any regulatory agency, exchange or listing authority, and politicians, political candidates or employees of any political party.

Third Parties means any person or company you encounter during your work for us. It includes actual or potential clients, customers, suppliers, distributors, business contacts, agents, advisors, government and public bodies, including their advisors, representatives and officials, politicians and political parties.

3. General principles

Vinco Recruitment is committed to acting professionally, fairly and with integrity in all our business dealings and relationships and take a zero-tolerance approach to bribery and corruption. This applies to wherever we operate.

The Company will act quickly against any potential malpractice to ensure it always conducts its business with the highest standards of integrity and honesty.

We are committed to educating our employees on the requirements of this policy and embedding its standards and requirements throughout the organisation.

All Employee’s must raise any concerns they may have about potential bribery and corruption immediately.

4. Your responsibilities

This policy sets out our zero-tolerance approach to bribery and corruption but does not provide exhaustive guidance for every possible bribery and corruption risk, examples include but are not limited to:

It is your responsibility to be alert to bribery and corruption risks, provide information to your line manager about these risks, and seek further guidance from the Legal Team as necessary.
You must not offer, give, request or accept bribes, whether directly or indirectly (such as bribes made through a third party), to or from any entity or individual.
Bribes are strictly prohibited in all circumstances but interactions with Public Officials present a heightened bribery risk.
You must not make Facilitation Payments of any kind, whether directly or indirectly (i.e., through another person or company), even if they are customary business practice in a particular country.
All Gifts, Hospitality or Charitable Donations that you give or receive must comply with this policy and our GH&C Policy).
You must not use Vinco Recruitment funds for Political Contributions. If you are unsure if your donor contribution constitutes a Political Contribution, you must consult the Legal Team or the Head of Business Integrity.
You must report known or suspected violations of this policy.
A non-exhaustive list of bribery and corruption Red Flags in relation to Third Party behaviour is contained at Annex A to this policy and you must familiarise yourself with this.
If you observe, become aware of or suspect conduct has occurred that violates this policy or otherwise implicates Vinco Recruitment in bribery or corruption, you must notify Vinco Recruitment immediately, in line with the procedure set out in section 5 below.

5. Reporting concerns

Concerns relating to any actual, alleged or suspected breach of this policy can be raised via several channels, including:

Your line manager
A member of the Senior Leadership Team/Directorate

We take any claims of retaliation, reprisal or detrimental treatment against anyone because of them raising a concern or assisting in an investigation very seriously. We will deal with retaliation by taking disciplinary action to protect those who do the right thing by speaking up.

6. Communication

This policy is communicated to our people when it is updated and is available on our OneDrive. Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.

7. Monitoring and review

Vinco Recruitment will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.

8. Consequences of breach

Failure to comply with this policy will be a disciplinary offence and may result in disciplinary action up to and including dismissal. In extreme cases, breach could be a criminal offence and could result in law enforcement agencies acting against you and/or Vinco Recruitment.

9. Enquiries

This policy is owned by the Vinco Recruitment leadership team. Please contact a director if you have any enquiries relating to this Policy.

Tax Evasion Policy

Anti-Tax Evasion Policy

In light of the Criminal Finances Act 2017, Vinco Recruitment has adopted a statement of our corporate policy on anti-tax evasion.

It is our policy to conduct all of our business dealings in an honest and ethical manner. The policy statement governs all our business dealings and the conduct of all persons or organisations who are appointed to act on our behalf.

We request all our employees and all who have, or seek to have, a business relationship with Vinco Recruitment to familiarise themselves with our anti-tax evasion policy and to act at all times in a way which is consistent with our anti-tax evasion policy.

1. Anti-tax evasion value statement

Vinco Recruitment has a zero-tolerance approach to all forms of tax evasion, whether under UK law or under the law of any foreign country.

Employees and Associates of Vinco Recruitment must not undertake any transactions which:

cause Vinco Recruitment to commit a tax evasion offence; or
facilitate a tax evasion offence by a third party who is not an associate of Vinco Recruitment.

We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter tax evasion facilitation.

At all times, business should be conducted in a manner such that the opportunity for, and incidence of, tax evasion is prevented.

2. Who must comply with this policy?

This policy applies to all persons working for Vinco Recruitment or any subsidiary company within Vinco Recruitment or on our behalf in any capacity, including employees at all levels, directors, officers and Associates (as defined below), including but not limited to agency workers, seconded workers, volunteers, interns, contractors, external consultants, third-party representatives and business partners, sponsors or any other person associated with us, wherever located.

3. Who is responsible for this policy?

The Board of Directors of Vinco Recruitment has overall responsibility for ensuring that this policy complies with our legal obligations, and our employees and associates comply with it. This policy is adopted by Vinco Recruitment. It may be varied or withdrawn at any time, at the Directors’ absolute discretion. Employees in leadership positions are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it.

4. What is the facilitation of tax evasion?

Associates includes Group contractors or an agent of Vinco Recruitment (other than a contractor) who is acting in the capacity of an agent, or any person who performs services for and on behalf of Vinco Recruitment who is acting in the capacity of a person or business performing such services.

Tax Evasion means an offence of cheating the public revenue or fraudulently evading UK tax, and is a criminal offence. The offence requires an element of fraud, which means there must be deliberate action, or omission with dishonest intent.

Tax Evasion Facilitation means being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of tax (whether UK tax or tax in a foreign country) by another person, or aiding, abetting, counselling or procuring the commission of that offence. Tax evasion facilitation is a criminal offence, where it is done deliberately and dishonestly.

Tax evasion is not the same as tax avoidance or tax planning. Tax evasion involves deliberate and dishonest conduct. Tax avoidance is not illegal and involves taking steps, within the law, to minimise tax payable (or maximise tax reliefs).

Tax means all forms of UK taxation, including but not limited to corporation tax, income tax, value added tax, stamp duty, national insurance contributions and includes duty and any other form of taxation (however described).

Examples of tax evasion can include (but are not limited to):

Under-reporting income; or
Inflating expenses or allowances; or
Hiding money or not declaring assets; or
Hiding profits in offshore accounts; or
Not submitting a tax return.

Indicators of tax evasion can include (but are not limited to):

Sounds too good to be true; or
Pay in the form of loans that are not expected to be paid back; or
High benefits which are disproportionate; or
Money is moved around in circles; or
Anything unusual about the way an associate or third party is conducting their relationship with Vinco Recruitment; or
Anything unusual about the associate’s or third parties conduct or behaviour in your dealings with them; or
Any unusual payment methods; or
A reluctance to provide applicable documentation on request.

5. Responsibilities

Vinco Recruitment has procedures governing certain transactions designed to prevent specific areas of possible tax evasion.

Vinco Recruitment is responsible for offering employees appropriate training to understand tax evasion, and actions to take to prevent tax evasion.

6. What team members and associates must do

Employees and Associates must at all times adhere to Vinco Recruitment' anti-tax evasion policy statement and must ensure that they read, understand and comply with this policy.

7. What team members and associates must not do

Engage in any form of facilitating Tax Evasion; or
Aid, abet, counsel or procure the commission of a Tax Evasion offence by another person; or
Fail to promptly report any request or demand from any third party to facilitate the fraudulent Evasion of Tax by another person, in accordance with this policy; or
Engage in any other activity that might lead to a breach of this policy; or
Threaten or retaliate against another individual who has refused to commit a Tax Evasion offence or who has raised concerns under this policy.

8. Prevention through vigilance

There is not an exhaustive list of Tax Evasion opportunities. At a more general level, the best defence against Tax Evasion and facilitation of Tax Evasion remains the vigilance of our employees and Associates and the adoption of a common-sense approach supported by our clear whistleblowing procedure.

9. How to raise a concern

Our employees have a responsibility to take reasonable action to prevent harm to Vinco Recruitment and we hold our employees accountable for their actions and omissions. Any actions that breach the Criminal Finances Act and the tax laws of wherever we operate brings harm to Vinco Recruitment and will not be tolerated.

You are responsible for properly following Vinco Recruitment' policies and procedures. These should generally ensure that all taxes are properly paid. If you are ever asked by anyone either inside or outside our Group to go outside our standard procedures, this should be reported without delay, as someone may be attempting to evade tax.

10. What happens if the employee prefers not to report their suspicions?

This should never happen. If there is any suspicion of tax evasion whether actual or intended, Vinco Recruitment are at risk of being criminally prosecuted and subjected to a large fine.