Regulatory Framework

Last Modified: 03 October, 2024

  • Introduction 

Centrally Focused Solutions LTD (“we”, “our”, or “us”:) is committed to ensuring the privacy and protection of all personal data we process. This Policy (“Data Protection Policy” or “Policy”) outlines how we collect, use, store, and protect personal data in compliance with UK's Data Protection Legislation, the UK General Data Protection Regulation (UK-GDPR) and the Data Protection Act 2018.

 

  • Scope

This Policy applies to all employees, contractors, suppliers, and any third parties who process personal data on behalf of Centrally Focused Solutions LTD.

 

  • Key Definitions
  • Personal Data: Any information relating to an identified or identifiable natural person (data subject).
  • Processing: Any operation performed on personal data, such as collection, recording, organisation, storage, use, or disclosure.
  • Data Controller: The entity that determines the purposes and means of processing personal data.
  • Data Processor: The entity that processes personal data on behalf of the controller.

 

  • Principles of Data Protection

We are committed to ensuring that personal data is:

  • Processed lawfully, fairly, and transparently.
  • Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
  • Adequate, relevant, and limited to what is necessary.
  • Accurate and, where necessary, kept up to date.
  • Kept in a form that permits identification of data subjects for no longer than necessary.
  • Processed in a manner that ensures appropriate security.

 

  • Legal Basis for Processing

Centrally Focused Solutions LTD ensures that we only process personal data when we have a lawful basis to do so, including:

  • The performance of a contract with the data subject.
  • Compliance with a legal obligation.
  • Legitimate interests pursued by the company or a third party, provided such interests are not overridden by the rights of the data subject.
  • Consent from the data subject.

 

  • Data Subjects' Rights

Data subjects have the following rights concerning their personal data: 

  • The right to access their personal data;
  • The right to rectification of inaccurate or incomplete data;
  • The right to erasure (“right to be forgotten”);
  • The right to restrict processing;
  • The right to data portability;
  • The right to object to processing based on legitimate interests;
  • The right to withdraw consent at any time (where consent is the lawful basis for processing).

 

  • Data Retention

We will retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. After this period, data will be securely deleted or anonymised.

 

  • Data Security 

We implement appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access.

These include:

  • Encryption of data;
  • Access controls and authentication;
  • Regular security assessments and audits.

 

  • Breach Notification

In the event of a data breach, Centrally Focused Solutions LTD will:

  • Notify the Information Commissioner’s Office (ICO) within 72 hours of becoming aware of the breach if it is likely to result in a risk to the rights and freedoms of individuals.
  • Notify affected individuals where there is a high risk to their rights and freedoms.

 

  • Training and Awareness

All employees and contractors who handle personal data are trained on their responsibilities under data protection laws and this Data Protection Policy. Regular refresher training will be provided.

 

  • Roles and Responsibilities

While we do not have a designated Data Protection Officer, our Head Of Compliance will oversee compliance with this Policy and data protection laws. All employees are responsible for ensuring that they follow this Policy when handling personal data.

 

  • Changes to This Policy

We may update this Policy from time to time to reflect changes in the law or our practices. Any updates will be communicated to all staff.

 

  • Contact Information

For any questions regarding this Policy or our data protection practices, please contact us at info@centrallyfocusedsolutions.co.uk.

Last Modified: 03 October, 2024

  • Introduction

At Centrally Focused Solutions LTD, we are committed to creating a diverse and inclusive working environment where all individuals are treated with respect and dignity. We believe that promoting equality and embracing diversity enriches our workplace, enhances our services, and helps us meet the diverse needs of our clients and community.

This Policy (“Equality & Diversity Policy” or “Policy”) outlines our commitment to providing equal opportunities and promoting diversity in the workplace, ensuring compliance with the Equality Act 2010 and all other relevant UK legislation.

  • Scope

This Policy applies to all employees, contractors, clients, suppliers, and any other stakeholders interacting with Centrally Focused Solutions LTD, across all our business operations.

  • Our Commitments

We are committed to:

  • Promoting equality of opportunity for all, irrespective of race, gender, disability, religion, age, sexual orientation, marital status, or any other characteristic protected by law.
  • Creating an inclusive working environment where individual differences and contributions are recognised and valued.
  • Providing a workplace free from harassment, bullying, victimisation, and unlawful discrimination.
  • Reviewing our practices, policies, and procedures regularly to ensure they align with equality legislation and reflect best practices in promoting diversity.

 

  • Equal Opportunities in Employment
  • - Recruitment and Selection

We aim to recruit and retain a diverse workforce. Recruitment decisions will be made based solely on merit, qualifications, and the abilities necessary for the job position, without any form of discrimination.

  • - Training and Development

We are committed to providing training opportunities that promote equality and diversity and help our employees understand and appreciate the value of diversity in the workplace.

  • - Pay and Benefits

We ensure that all employees receive equal pay for work of equal value, without discrimination.

  • - Promotion

Promotions are based on merit and the ability to perform the job to the required standard, regardless of personal characteristics.

 

  • Anti-Discrimination and Harassment

Discrimination, harassment, bullying, or victimisation will not be tolerated at Centrally Focused Solutions LTD. Any employee found to have breached this Policy may face disciplinary action, which could result in dismissal for gross misconduct.

 

  • Responsibilities
  • - Management

Senior management is responsible for ensuring that this Policy is implemented and reviewed regularly, and that the workplace is free from discrimination and harassment.

  • - Employees

Every employee is responsible for upholding this Policy, treating colleagues, clients, and partners with respect, and reporting any incidents of discrimination, bullying, or harassment.

 

  • Reporting and Complaints Procedure

If an employee or other stakeholder believes they have been subject to discrimination, harassment, or bullying, they should report the issue immediately to their line manager or HR department. All complaints will be taken seriously and investigated promptly and confidentially.

 

  • Monitoring and Review

We will monitor the effectiveness of this Policy and make necessary adjustments to ensure continued compliance with equality legislation. This Policy will be reviewed annually, or sooner if required by changes in legislation.

 

  • Conclusion

We believe that promoting equality and diversity not only reflects our values but also contributes to the success of Centrally Focused Solutions LTD by fostering a more creative, innovative, and productive environment.

Last Modified: 03 October, 2024

At Centrally Focused Solutions LTD (“Centrally Focused Solutions LTD” or “Company” or “We”), ethical business conduct is a cornerstone of our operations. We are dedicated to upholding the highest standards of ethics across all levels of the Company, and this Policy outlines our core principles.

Integrity and Transparency

We are committed to conducting all business activities with honesty, integrity, and transparency. Our team members and stakeholders, partners and/or contractors, are expected to act ethically in all dealings with clients, colleagues, partners, and suppliers.

Respect for Human Rights

Centrally Focused Solutions LTD upholds and promotes the principles of human rights as set forth by the Universal Declaration of Human Rights. We do not tolerate any form of forced labour, child labour, or exploitation. 

Fair Competition

We believe in fair and open competition. We will not engage in unethical practices to gain an unfair advantage in the market. We aim to compete honestly based on the quality and value of our services.

Social Responsibility

As part of our commitment to the communities in which we operate, we support charitable activities, community engagement, and practices that promote the well-being of society.

Data Protection and Privacy

We adhere to all relevant data protection laws, including the UK Data Protection Act 2018 and GDPR. We are committed to safeguarding the personal information of our stakeholders, clients, contractors, and partners.

Ethical Decision-Making

Our team members at all levels are encouraged to apply ethical considerations in decision-making processes. If in doubt, all team members are urged to consult their line manager for guidance.

Reporting Unethical Behaviour

We are committed to creating an environment where our team members and/or partners and contractors feel comfortable reporting unethical or illegal activities. We have a Whistleblowing Policy in place, ensuring confidentiality and protection against retaliation.

Accountability

Our Company is responsible for upholding the Company's ethical standards. Breaches of this Policy will result in appropriate disciplinary action, which may include termination of our cooperation with our team members, partners and contractors or legal action, depending on the severity.

Last Modified: 03 October, 2024

At Centrally Focused Solutions LTD (“Centrally Focused Solutions LTD” or “Company” or “We”), we are committed to maintaining the highest standards of integrity, professionalism, and ethical behaviour. This Code of Conduct outlines the principles and expectations that guide our stakeholders, contractors, and partners.

  • Compliance with Laws and Regulations 

All stakeholders of Centrally Focused Solutions LTD must comply with applicable laws and regulations, including local, national, and international laws relevant to our business operations. 

  • Professionalism

We expect all team members to conduct themselves in a professional and respectful manner at all times. This includes punctuality, treating colleagues and clients with respect, and maintaining a professional appearance.

  • Confidentiality

Our Company protects confidential information related to our business, clients, and partners. Sharing sensitive information without proper authorisation is strictly prohibited.

  • Conflict of Interest

Our Company avoids any conflicts of interest that could compromise our integrity. Any partners or contractors must disclose any situation where personal interests may conflict with Company interests.

  • Equal Opportunities

The Company is an equal opportunity company. We do not tolerate discrimination or harassment of any kind, based on race, gender, age, disability, sexual orientation, religion, or any other protected characteristic. 

  • Health and Safety

We are committed to providing a safe and healthy work environment. Our Company is expected to follow health and safety guidelines, report hazards, and act responsibly to prevent accidents.

  • Environmental Responsibility

We recognise our responsibility to minimise our environmental impact. Our Company supports initiatives that reduce waste, conserve energy, and contribute to sustainability.

  • Anti-Bribery and Corruption

The Company maintains a zero-tolerance policy on bribery and corruption. Our Company and its partners are prohibited from offering, accepting, or facilitating bribes or unethical incentives in any form.

 

Last Modified: 03 October, 2024

  • Introduction

At Centrally Focused Solutions LTD (“Company” or “We”), we are committed to preventing money laundering and the financing of terrorism. This Anti-Money Laundering (AML) Policy (“Anti-Money Laundering (AML) Policy” or “Policy”) outlines our commitment to comply with UK regulations and global standards to detect, prevent, and report suspicious activities. We take our responsibility seriously to ensure that our business is not used to facilitate financial crime. 

 

  • Legal Framework

 

  • This Policy complies with the UK’s anti-money laundering regulations, including but not limited to:
  • The Proceeds of Crime Act 2002 (POCA)
  • The Terrorism Act 2000
  • The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
  • The Financial Conduct Authority (FCA) rules and guidance

 

  • Objectives

Our AML Policy is designed to:

  • Prevent the use of Company’s services for money laundering or terrorist financing.
  • Identify, assess, and mitigate risks related to money laundering.
  • Ensure proper reporting of suspicious activities to the relevant authorities.
  • Maintain records of customer identification and transactions in compliance with the applicable law.

 

  • Customer Due Diligence (CDD)

We perform thorough due diligence to verify the identity of all our clients. This includes:

  • Identifying and verifying the identity of clients using official documents such as passports, driving licences, and utility bills.
  • Performing enhanced due diligence (EDD) for higher-risk clients, such as those from high-risk countries or politically exposed persons (PEPs).
  • Ensuring ongoing monitoring of business relationships and transactions to detect and report suspicious activity.

 

  • Risk Assessment

The Company adopts a risk-based approach to AML, where the level of scrutiny varies based on the client’s risk profile. This process includes:

  • Identifying potential risks based on client activity, geographic location, and transaction type.
  • Implementing appropriate controls for mitigating identified risks.
  • Regularly reviewing and updating our risk assessment procedures.

 

  • Reporting Suspicious Activities

Employees are required to report any suspicious activity to the company’s Money Laundering Reporting Officer (MLRO). The MLRO will:

  • Investigate the report and decide whether it should be escalated to the National Crime Agency (NCA).
  • Submit a Suspicious Activity Report (SAR) where necessary.
  • Ensure confidentiality of the report and that no tipping-off occurs.

 

  • Training

All Company’s employees or contractors are provided with regular AML training to ensure they understand:

  • The importance of AML compliance.
  • How to identify suspicious transactions and behaviours.
  • The reporting procedures for suspicious activity.

 

  • Monitoring and Review

This AML Policy will be reviewed and updated regularly to ensure ongoing compliance with legal requirements and best practices. The Company also conducts internal audits to monitor the effectiveness of our AML controls and procedures.

 

  • Contact Information

For further information regarding this Policy, or if you wish to report suspicious activity, please contact our Company at info@centrallyfocusedsolutions.co.uk.

 

Last Modified: 03 October, 2024

  • Introduction

At Centrally Focused Solutions LTD (“Company”), we are committed to conducting business with the highest standards of integrity, honesty, and accountability. We expect all employees to maintain these standards in everything they do. However, if you have any concerns about wrongdoing or unethical behaviour within the organisation, we encourage you to report it through our whistleblowing procedure.

Whistleblowing refers to raising concerns about unlawful conduct, fraud, health and safety risks, or other activities that could harm the organisation, its employees, or the public.

 

  • Purpose of the Policy

This Policy (“Whistleblowing Policy” or “Policy”) is designed to:

  • - Encourage employees to raise concerns about suspected misconduct, malpractice, or dangers within the company without fear of victimisation or reprisal.
  • - Ensure that such concerns are dealt with promptly, professionally, and confidentially.
  • - Outline the procedure for reporting and handling whistleblowing concerns.

 

  • What is Whistleblowing?

Whistleblowing refers to the reporting of suspected or actual illegal, unethical, or improper conduct. Concerns that may be raised under this Policy include, but are not limited to:

  • - Criminal activity or illegal conduct;
  • - Health and safety risks, including risks to the public or employees;
  • - Fraud, corruption, or financial misconduct;
  • - Environmental damage;
  • - Miscarriages of justice;
  • - Failure to comply with legal or regulatory obligations;
  • - Deliberate concealment of any of the above.

Concerns related to personal grievances (such as bullying or harassment) should be addressed under the Company's Equality & Diversity Policy.

  

  • Who Can Raise a Concern?

Any employee, contractor, or business partner who suspects wrongdoing within Centrally Focused Solutions LTD is encouraged to raise their concerns. All concerns will be treated seriously and investigated promptly.

 

  • Protection and Confidentiality

We understand that raising a concern can be a difficult decision. Employees who whistle blow will be protected from any form of retaliation, including dismissal, disciplinary action, or victimisation. Whistle-blowers can remain anonymous, although it may be easier to investigate concerns if the individual is willing to provide their name.

 

  • How to Raise a Concern
  • - Concerns can be raised through the entitled Line Manager, who, in most cases, should be your first point of contact.
  • - When raising a concern, please provide as much detail as possible, including any evidence or information that may support your report.

 

  • Handling the Concern

Once a concern is raised, we will:

  • - Acknowledge the receipt of the concern within ten [10] days.
  • - Assess the concern to determine the appropriate course of action.
  • - Investigate the matter thoroughly, ensuring confidentiality is maintained.
  • - Provide feedback on the outcome of the investigation, where appropriate.

 

If it is found that misconduct or wrongdoing has occurred, appropriate action will be taken in line with the company’s disciplinary procedures.

 

  • External Disclosure

While we encourage concerns to be raised internally, we understand that whistle-blowers may feel it necessary to report the issue to an external party such as a regulator. It is important to ensure that external disclosures are made to the appropriate body to remain protected under the Public Interest Disclosure Act 1998 (PIDA).

 

  • False Allegations

Anyone who deliberately makes a false allegation, with malicious intent, may face disciplinary action. However, if an employee raises a concern in good faith, even if it turns out to be unfounded, they will not face any consequences.

  

  • Review of Policy

This Policy will be regularly reviewed and updated to ensure it remains in line with legal requirements and best practices.

This Policy demonstrates Centrally Focused Solutions LTD commitment to fostering a transparent and ethical working environment, where employees feel empowered to report concerns without fear of reprisal.

 

CONTACT US

Upgrade

your workflow

Start Now