Codes and Policies
- Code of Conduct and Competition Law Compliance Policy
- Environmental Policy Statement
- Equality Policy
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
How we use your information?
This privacy notice tells you how we, IBP Global Trading Ltd, will collect and use your personal data to provide services and products- this can include financial information, contact information, cookies, ID addresses, marketing preferences.
Why do we need to collect and store personal data?
In order for us to provide you with products and services we need to collect personal data to contact you and administer your account. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
Before contacting you for marketing purposes, IBP Global Trading Ltd would always contact you for additional consent.
For marketing activities, the information we collect and use may include:
- Any personal details that you submit such as your name, address, telephone number, email address, date of birth or other information provided
- Your IP address which we use to note your visit
This personal data may be held and used for the following activities:
- Allowing you to participate in specialist online training
- Answer your enquiries
- Send you competition prizes
- Send newsletters (if opted in)
- Create case studies
- Record your certification for product training
Will IBP Global Trading Ltd share my personal data with anyone else?
We may pass your personal data on to third-party service providers contracted to IBP Global Trading Ltd in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely and to use it only for those purposes we have defined. When your data is not longer needed, they will dispose of the details in line with IBP Global Trading Ltd’s procedures. If we wish to pass any of your special category personal data onto a third party, we will only do so once we have obtained your consent, unless we are legally required to do otherwise.
How will IBP Global Trading Ltd use my personal data?
IBP Global Trading Ltd will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. IBP Global Trading Ltd is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Under what circumstances will IBP Global Trading Ltd contact me?
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Can I find out the personal data that the organisation holds about me?
At your request, IBP Global Trading Ltd can confirm what information we hold about you and how it is processed. If IBP Global Trading Ltd does hold personal data about you, you can request the following information:
- Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
- Contact details of the data protection officer.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of IBP Global Trading Ltd or a third party, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time. Privacy Notice- public 3 IBP GLOBAL TRADING LTD– 01.05.18 • How to lodge a complaint with the supervisory authority.
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
How can I access the personal data you hold on me?
You will need to put your request in writing to our Data Protection Officer with evidence of your identity (passport, ID card, driving licence, birth certificate).
Contact details of the Data Protection Officer
Data Protect Officer
Global House, 95 Vantage Point
The Pensnett Estate
Kingswinford DY6 7FT
Tel: +44 121 5212913
Code of Conduct
It is a requirement of the board that IBP Group and its subsidiaries, complies with the laws of the relevant countries in which it operates. This includes compliance with the applicable competition laws in each country.
Competition Law Compliance Policy
Each employee whose job role means that they could engage in anti-competitive behaviour shall receive competition law compliance training as part of their induction programme.
In the case of internal promotions, each employee whose job role changes such that they could engage in anti-competitive behaviour, and who did not receive competition law compliance training when recruited, shall receive such training at the time, or before their promotion becomes effective.
Each employee whose job role means that they could engage in anti-competitive behaviour shall undergo refresher training on competition law compliance by such means and at such frequencies as the company shall determine.
Each employee has a duty to act in a manner which is compliant with competition law in all dealings on behalf of the company.
It is impracticable to cover all of the activities which may be within the realm of an infringement of competition law. If in doubt as to whether or not a particular action, transaction or course of dealings complies with competition law, guidance should be sought from your manager.
Each employee whose job role means that they could engage in anti-competitive behaviour shall receive competition law compliance training as part of their induction programme.
However, essential guidelines for implementing the Policy are as follows:
You must conduct yourself in such a way as to enable the company to maintain independence in the market place and you must respect the independence of the company’s competitors, customers and suppliers;
You must conduct yourself in such a way to enable the company to compete vigorously on the market at all times, and you must ensure that coordination with competitors is avoided;
You must not participate in, or cause the company to become a party to, any arrangement, express or implied , written or unwritten, with particular customers or suppliers: to fix prices; or share markets in a manner which would contravene competition law;
You must not disclose to, either directly or indirectly, or receive from the company’s competitors commercially sensitive information from customers;
You must not engage in activities designed to prevent or hinder legitimate parallel trade in the EU. For example, you must not prevent products from being exported to a country in the EU when the products have already been put on the market in another country in the EU;
You must conduct yourself in such a way so that the company does not prevent its distributors from buying/selling/re-selling competing products after the termination of the contract.
Conduct your business dealings and activities in accordance with this Policy;
Complete a quarterly competition compliance declaration to confirm that you have adhered to the requirements of the code of conduct and competition law compliance policy
Complete and submit a report to the Group HR Director following any form of contact with competitors. Any sensitive data will be removed and the report which will be forwarded to the Group Commercial Director for recording in the competition compliance log;
Comply with competition law at all times;
Report any activity, transaction or course of dealing which you suspect may infringe competition law
Reporting of Breaches and Accountability
Any employee who becomes aware of any existing or potential breach of this policy is required to notify the Group Commercial Director promptly. If preferred, concerns about any existing or potential breaches may be reported in accordance with the company’s whistle blowing policy.
In enforcing this Policy, the company will take such disciplinary action as it deems appropriate, up to and including dismissal of the individual (s) responsible.
IBP Group Compliance Report
Name of person submitting this report: _________________________
Company Employed by: _____________________________________
Date of report: _____________________
Please provide full details.
Including date/place/location/who was involved and full details of the event including verbal conversations
Declaration of compliance with competition law
I declare that during the period ______________________.
I have submitted a report to Lorraine Mildner giving full details of any contacts I have had (whether formal, informal or social, oral or written) with competitors, including those at trade association meetings;
I have not discussed any of IBP’s conditions of supply, purchase pricing policies, price levels or other terms of trade with any supplier, joint venture partner, customer or competitor, other than with the party to which they apply;
I confirm that I have gained prior authority from Lorraine Mildner & Richard Darwin to attend any trade associations meetings;
I have passed all agendas, minutes and reports from trade associations which I have attended or which I have received or am aware of, to Richard Darwin;
I have not discussed or communicated in any manner, any of IBP’s confidential or commercially sensitive information with anyone other than the party to which it applies;
I have complied with IBP’s competition policy and, so far as I am aware, the provisions of all relevant competition legislation and
I have no concerns about my own or my company’s compliance with competition law.
This declaration is true. I understand that the provision of any untrue information on this Declaration may constitute a disciplinary offence.
Conex Universal Limited is a UK based business part of IBP group. The business specialises in the design, manufacture and supply of plumbing fittings and valves to customers in the domestic, commercial, industrial, HVAC and shipbuilding markets worldwide.
The business is committed to protecting the local and global environment and to minimize environmental impacts concerning its activities, products, and services.
To achieve this Conex Universal Limited operates an Environmental Management System (EMS) in accordance with the requirements of ISO 14001:2015
The company leadership team fully supports the EMS and shall:
- Comply with applicable legal and other requirements to which the company subscribes which relate to its environmental Aspects.
- Include the consideration of environmental issues in all business strategies and initiatives.
- Prevent pollution, reduce waste and minimize consumption of resources. Educate, train and encourage, employees, suppliers and subcontractors to carry out tasks in an environmentally responsible manner.
- Maintain key processes such as internal audits, monitoring, corrective/preventive action and management reviews to achieve the set objectives & targets.
- Ensure that the adequate resources needed for an effective EMS are available. Promote continual improvement of environmental performance.
This policy will be communicated to all employees and organisations working for or on our behalf.
The policy is available on company website (here) to all interested parties.
Group Chief Executive
We are committed to eliminating discrimination amongst our workforce. Our objective is to create a working environment in which there is no unlawful discrimination and all decisions are based on merit.
This policy has the full support of our board of directors.
Status of this policy
This policy does not give contractual rights to individual employees. The company reserves the right to alter any of its terms at any time although we will notify you in writing of any changes.
This policy applies to all employees, workers, agency workers, contractors and job applicants.
Responsibility for this policy
The Group HR Director is responsible for this policy.
What is discrimination?
Discrimination is unlawful when it takes place on one of the following grounds (the ‘protected characteristics’):
• gender re-assignment
• marriage and civil partnership
• pregnancy and maternity
• ethnic or national origin
• religion or belief
• sexual orientation
Discrimination can take a number of forms:
• Direct discrimination is when someone is treated worse than someone else just because of a protected characteristic. For example, it would be direct discrimination if a manager excludes an employee from a training course just because she is gay.
• It is also direct discrimination when someone is treated worse than someone else because they associate with someone with a protected characteristic or because they are perceived to have a protected characteristic. For example, it would be direct discrimination if an employee ostracised a colleague because the colleague has a gay flatmate or because he thinks the colleague is gay.
• Indirect discrimination is when an apparently neutral practice or requirement disproportionately disadvantages one group and cannot be justified by the needs of the business. For example, imposing a requirement that job applicants must speak fluent English disproportionately disadvantages non-English groups and would be unlawful unless it could be justified on genuine business grounds.
• It is also discrimination when a disabled person is treated unfavourably because of something connected to their disability and this cannot be justified by the needs of the
business or when the business fails to make reasonable adjustments for a disabled person.
Our responsibilities and approach
We aim to avoid discrimination in all aspects of employment and recruitment. Our approach to different aspects of employment and recruitment is set out below.
Recruitment and selection
We aim to ensure that job requirements and job selection criteria are clear and based only what is required to get the job done effectively. We will avoid making stereotypical assumptions based on protected characteristics about who is able to do a particular job.
We aim to ensure that no job applicant is placed at a disadvantage by practices or requirements which disproportionately disadvantage protected groups and which are not justified by the demands of the job.
For all jobs, we will draw up a clear and accurate job description and person specification to ensure that we remain focussed on what the job involves and the skills, experience and qualifications which are relevant and necessary to do the job. If a job can be done flexibly, we aim to say so in the job description.
We will not ask for personal or irrelevant information on application forms or in interviews. We will focus instead on whether someone has the relevant skills, qualities and experience to do the job.
Promotion, training and appraisals
Promotion and training decisions will be made on the basis of merit. We will not unlawfully discriminate against any employee in making promotion or training decisions. We believe all employees should have an equal opportunity to progress and develop.
We will advertise promotion and transfer opportunities widely, including deputising opportunities and secondments which could lead to permanent promotion. We will try to ensure that training and development opportunities are made known to all relevant employees.
Training needs will be identified through regular reviews with your line manager. We have a formal review system which helps us to ensure that employees are being assessed fairly on the basis of job performance and are not being discriminated against. We will conduct reviews objectively and measure performance in a transparent and objective way, without prejudice or bias.
We aim to ensure that our terms of employment, benefits, and policies are free from unlawful discrimination.
We will ensure that decisions made under our disciplinary, grievance and attendance management policies are carried out fairly and without discrimination.
Termination of employment
We will ensure that we avoid discrimination in making decisions about dismissal or redundancy.
Where possible we will ensure that any manager’s decision to dismiss an employee is endorsed by another manager and the HR department. We will encourage leavers to give feedback about their employment in exit interviews
We will make adjustments to accommodate disabled employees where possible and reasonable. For example, we can provide extra equipment or support, we can re-arrange duties and we can make changes to our premises in appropriate cases. If you think you may have a disability, you are encouraged to tell the business about this so that we can explore what adjustments might be appropriate.
Your rights and responsibilities
You have the right not to experience unlawful discrimination in our workplace. You also have a responsibility to understand this policy and help us to implement it.
All employees’ workers, agency workers and contractors have a duty not to discriminate against each other and not to help anyone else do so.
Our relationships with visitors/customers/suppliers
You must not discriminate against any of our visitors, customers or suppliers. Equally, we expect our visitors, customers or suppliers not to discriminate against you and we will take appropriate action against any visitor, customer or supplier found to have done so.
What to do if you have been discriminated against
If you believe you may have been discriminated against, please tell us. You can speak informally with your manager or anyone in HR. If you want to make a more formal complaint, you are encouraged to raise the matter through our Grievance procedure. If you believe there has been any bullying or harassment then you should raise the matter through our Bullying and harassment procedure.
Allegations of potential breaches of this policy will be treated seriously. Employees and contractors who make such allegations in good faith will not be victimised or treated less favourably as a result. However, false allegations of a breach of this policy which are found to have been made in bad faith will be dealt with under our disciplinary procedure.
What will happen if you act in a discriminatory way?
If, after investigation, we decide that you have acted in breach of this policy you may be subject to disciplinary action up to and including dismissal. This applies to the most senior levels of management as well as to all other employees.
Policy review and promotion
We will promote and publicise our Equality Policy as widely as possible using our intranet, website, application packs, induction packs and handbooks.
We will review our Equality Policy on a regular basis.