Main Portfolio Policies

Website Privacy Policy

1. Introduction

1.1 Main Portfolio LTD (“We” and “Our Company”) takes the privacy of your personal data very seriously, and we do so in accordance with the European General Data Protection Regulation (GDPR), the Data Protection Act 2018 and Privacy and Electronic Privacy Regulations (PECR) and any other applicable legislation.

1.2 This Privacy Policy notice is served by our company under the Website mainportfolio.co.uk. The Policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of the users, the Website and Website owners. Furthermore, the Policy explains how this Website processes, stores and protects user data and information while you browse or use this Website.

1.3 We may update this Privacy Policy occasionally – you can find our latest Policy on our Website.

2. What type of Personal Data do we collect?

2.1 To fulfil our stated purposes, we neither collect more information nor retain it longer than is necessary.

2.2 The information we collect focuses on your usage of the Website. This includes:

Technical Data: information we collect automatically when you visit our Website or interact with us by email, including the device used to access the Website, its operating system, the connection type and the IP address;
Social Media Platforms Data: When you engage with us through social media platforms, we will use your social media username (if you interact with us through those channels) to help us respond to your comments, questions or feedback;
Identity & Contact Data: Your name and email address are required to respond to any enquiries you make when completing the contact form on our Website.

3. What is the information used for?

3.1 The information we collect from you when visiting our Website is used to analyse your activity on the site so that we can administer, support, improve and develop our business.

3.2 It is also used for statistical and analytical purposes.

3.3 Ultimately, this will allow us to optimise the customer experience.

4. Where does the information come from?

4.1 We collect your personal information when you interact with us, such as when you visit our Website or use our Contact Us form on the Website. Information about your use of our Website is collected by using cookies.

4.2 You can disable cookies if you wish to do so. Information, such as your name and email address, is collected when you complete the Contact Us form on our Website.

4.3 We may also collect personal information when you engage with us on social media platforms, complete any surveys we send to you or enter prize draws or competitions.

4.4 We rely on legitimate interest as a basis for processing your personal information when you contact us using the contact form on our Website or when you engage with us through social media channels.

4.5 We carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental privacy rights are not outweighed by our legitimate interest in processing that information. Before collecting your data from surveys or prize draws, we will request your consent.

5. Your Rights & Choices

5.1 Under data protection law, you have rights we need to make you aware of. The rights available to you depend on our reason for processing your information.

Your right of access:
You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process.
Your right to rectification:
You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies.
Your right to erasure:
You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing:
You have the right to ask us to restrict the processing of your information in certain circumstances.
Your right to object to processing:
You have the right to object to processing if we can process your information because the process is in our legitimate interests.
Your right to data portability
This only applies to the information you have given us. You have the right to ask that we transfer the information you provided us from one organisation to another or give it to you. The right only applies if we are processing data based on your consent or under or in talks about entering into a contract and the processing is automated.

5.2 You are not required to pay any charge for exercising your rights. We have one month to respond to you.

5.3 Please note – if we are holding your personal data on behalf of your employer as part of the services we offer as a business, then you should contact your employer directly to exercise any of your rights above.

6. Cookies Policy

6.1 Our Website puts small files (known as ‘cookies’) into your computer to collect information about how you use the Website and to improve the user experience while visiting the Website.

7. Cookies are used to:

7.1 Measure how you use the Website so that the site can be updated and improved based on your needs.

7.2 Remember the notifications you’ve seen, so we don’t show them to you again.

7.3 You will typically see a notification on our Website to remind you that we store a cookie on your file. Where applicable, this Website uses a cookie control system requesting to allow or disallow the use of cookies on their computer/device on their first visit to the Website. This complies with recent legislation requirements for Websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer/device.

7.4 The cookies in use to deliver Google Analytics results are described in the table below:

Name	Purpose	Expires
__utma	Counts how many of our visitors are new to our website or to a certain page.	This information is kept for 2 years.
__utmb	This works with _utmc to calculate the average length of time you spend on our website.	This information expires after 1 hour.
__utmc	This works with _utmb to calculate when you close your browser.	This information expires when you close your browser.
__utmv	Enables us to track what you visit on our website and measure site performance.	This information expires after 2 years.
__utmz	This tells us how you reached our website, e.g. from another website or a search engine.	This information expires after 6 months.

8. Security

8.1 The security of your personal information is vital to us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure.

8.2 While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

9. What is the information used for?

9.1 The information is sent to Google Analytics.

9.2 The information is stored on the Google server in the U.S. The data is collated via google analytics which is then used by the analytical team in the Marketing team to enhance the user experience when you visit our Website.

10. Opt-out

10.1 To give Website visitors more choices on how Google Analytics collects data, Google has developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with Google Analytics JavaScript (ga.js) to stop sending data to Google Analytics.

10.2 The Google Analytics Opt-out Browser Add-on does not affect Website usage in any other way.

10.3 A link to further information on the Google Analytics Opt-out Browser Add-on is provided below for your convenience: https://tools.google.com/dlpage/gaoptout?hl=None.

10.4 For more information on the usage of cookies by Google Analytics, please refer to the Google Website. A link to the privacy advice for this product is provided below for your convenience: https://policies.google.com/privacy.

11. Disabling Cookies

11.1 If you would like to restrict the use of cookies, you can do so through your Internet browser. Support for the most popular Internet browsers is provided in the links below for your convenience.

11.2 It will be available for the Internet browser of your choice either online or via the software help (usually available via key F1).

Microsoft Edge
https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09
Google Chrome
https://support.google.com/chrome/bin/answer.py?hl=en-GB&answer=95647&p=cpn_cookies
Mozilla Firefox
https://support.mozilla.org/en-US/kb/block-Websites-storing-site-preferences?redirectlocale=en-US&redirectslug=Blocking+cookies
Apple Safari
https://www.apple.com/privacy/manage-your-privacy/

12. Contact

12.1 Questions, comments, complaints and requests regarding this Policy are welcomed and should be addressed to our office address at K2 Tower 60 Bond Street, Silvester St Entrance, Hull, England, HU1 3EN, or to Legal Compliance Department at legal@mainportfolio.co.uk. In addition, please do not hesitate to contact us if you suspect any privacy or security breaches.

12.2 If you remain dissatisfied, you can make a complaint about the way we process your personal information to the Information Commissioner’s Office (ICO) as the UK supervisory authority.

Please follow this link to see how to do that at: https://ico.org.uk/make-a-complaint/.

Website Terms and Conditions

Please read these Terms and Conditions (“T&C” and “terms and conditions”) carefully before using mainportfolio.co.uk Website operated by Main Portfolio LTD.

1. Acceptance of Terms & Conditions

1.1 By accessing and using this Website, you agree to the following terms and conditions, which shall take effect immediately upon your first use. If you do not agree with these T&Cs, you should not access or use this Website.

1.2 These terms and conditions may change at any time and without prior notice. You should regularly check for relevant updates, and your continued use will be deemed as acceptance of any revised or amended terms.

1.3 If you do not agree with any changes, you should cease accessing or using this Website immediately.

2. Intellectual Property

2.1 Unless explicitly stated, all intellectual property in this Website or any of its content including, but not limited to, all copyrights, trademarks and names, service marks, text, graphics, branding, themes, and the Website design are the property of or licensed to, the owners of this Website, or under other lawful, authorised use.

2.2 You agree and acknowledge that by accessing this Website, you do so only for your personal use and benefit.

2.3 None of the content contained in this Website may be downloaded, copied, inverted, sold, rented, broadcasted, distributed or otherwise used for any commercial purpose.

2.4 You may download and copy content from this Website for personal and non-commercial use.

3. Content & Contributions

3.1 The Website owners may change or remove any section of this Website and its content, entirely or partially, without prior notice and free of any liability for any such changes.

3.2 None of this Website content shall be taken as advice or recommendations, professional or otherwise, and you should not rely upon this Website content to make any decisions or reach any conclusions.

3.3 Where this Website permits users to contribute content in any form, including but not limited to posting comments and uploading files (“User Contributions”), the following shall apply:

The Website owners bear no responsibility for user contributions or any distress, injury or damage these may cause;
The Website owners reserve the right to control user content that appears on this Website and may remove any user content, without prior notice, which they deem unfit or inappropriate, at their sole discretion.

4. Links to Third Party Websites & Resources

4.1 This Website may contain links or references to external websites or resources that are owned, controlled or hosted by third parties.

4.2 Any such link or reference is provided for your convenience only, and does not constitute an endorsement of, claim ownership over, or assumption of responsibility for any content of these external websites or resources by this Website or its owners.

4.3 The Website owners have no control over the content of these external websites or resources, and therefore accept no responsibility whatsoever, including for any loss or damage that may arise from their usage.

4.4 If you decide to access any of the third-party websites linked to this Website, you do so entirely at your own risk and subject to their terms and conditions of use and the policies (including privacy policies) of such external websites or resources.

5.Disclaimers & Liability

5.1 The Website owners make no warranty of any kind, whether expressed or implied in regards to any of the following:

The uninterrupted or stable availability and accessibility of this Website or any of its content;
The suitability or compatibility of this Website or its content with any computer system, software, or information storage or retrieval system;
The security of this Website, its content or any information the users submit;
The absence of viruses or malicious software, or machine-readable codes.

5.2 The Website owners indisputably, to the fullest extent permitted by law, shall bear no liability for any loss or damage, which may be caused by using or accessing this Website or its content directly, consequentially or in any other way.

5.3 Nothing in these terms or conditions shall be construed or interpreted as attempting to exclude or limit liability for death or personal injury resulting from the negligence of the Website owners or any of their agents or employees.

6. Jurisdiction & Severability

6.1 All clauses, sub–clauses and parts thereof shall be severable and read and construed independently. Should any part of these terms and conditions be found invalid, it will not affect the validity or enforceability of the remaining terms and conditions.

6.2 These terms and conditions shall be construed and interpreted following English law and shall be subject to the exclusive jurisdiction of the English Courts.

Data Protection Policy Statement

1. Introduction

1.1. Background to the UK-General Data Protection Regulation (‘UK-GDPR’)

This Policy is based on the UK-GDPR and the ICO’s guidance on the UK-GDPR and also complies with the Data Protection Act 2018, which defines the law of processing data on identifiable living people and most of it does not apply to domestic use. Anyone holding personal data for other purposes is legally liable to comply with this Act, with a few notable exceptions.
This Policy applies to all personal information processed by, or on behalf of our Company.
All personal data must be handled and dealt with appropriately however it is collected, recorded and used, and whether it is on paper, in electronic records or recorded in other formats, on other media, or by any other means. It includes information held on computers (including email), paper files, photographs, audio recordings and CCTV images.
The purpose of this Policy is to help you understand what personal data our Company collects, why we collect it and what we do with it. It will also help you to identify what your rights are and who you can contact for more information, to exercise your rights or to make a complaint.

1.2. Definitions according to Article 4 of the UK-GDPR

Personal data – 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;
Data controller – the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data;
Data processor – means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
Processing – any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
Personal data breach – a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;
Consent of the data subject – means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
Child – the UK-GDPR defines a child as anyone under the age of 13 years old. The processing of personal data of a child shall be lawful only if and to the extent that consent is given or authorised by the holder of parental responsibility over the child.
Third party – a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;
Filing system – means any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis;
Third country– means a country or territory outside the United Kingdom.

2. Data Protection Policy Statement

2.1. Main Portfolio LTD, is committed to compliance with all relevant domestic laws in respect of personal data, and the protection of the “rights and freedoms” of individuals whose information we collect and process in accordance with the UK-GDPR.

2.2. Compliance with the UK-GDPR is described by this Policy and other relevant policies such as the Information Security Policy (ISP) along with connected processes and procedures.

2.3. The UK-GDPR and this Policy shall apply to all of our Company’s data processing functions, including those performed on customers’, clients’, employees’, suppliers’, and partners’ personal data, and any other personal data the organisation processes from any source.

2.4. Our Company has established objectives for data protection and privacy, which are in the Personal Information Management System (PIMS).

2.5. Main Portfolio LTD shall be responsible for reviewing the register of data processing annually in the light of any changes to the Company activities and to any additional requirements identified by means of Data Protection Impact Assessment (DPIA).

2.6. This Policy applies to all Employees/Staff/Contractors/Clients/Partners and third-party providers of our Company. Any breach of the UK-GDPR will be dealt with as described under our Data Breach Notification Procedure and may also be a criminal offence, in which case the matter will be reported as soon as possible to the appropriate authorities.

2.7. Partners and any third parties working with or for our Company, and who have or may have access to personal data, will be expected to have read, understood and to comply with this Policy. No third party may access personal data held by our Company without having first entered into a Data Confidentiality Agreement, which imposes on the third-party obligations no less onerous than those to which our Company is committed, and which gives us the right to audit compliance with the agreement.

3. Personal Information Management System & Information Security Policy (PIMS/ISP)

3.1. To support compliance with the UK-GDPR, our Board has approved and supported the development, implementation, maintenance and continual improvement of a documented PIMS, which is integrated within the ISP, for our Company.

3.2. All our Employees/Staff and third-party providers identified in the inventory are expected to comply with this Policy and with the PIMS/ISP that implements this Policy. All Employees/Staff will receive appropriate training.

3.3. Scope:

The scope of the PIMS will cover all of the PII (Personally Identifiable Information) that the organisation holds including PII that is shared with external organisations such as suppliers, cloud providers, etc.

3.4. In determining its scope for compliance with the UK-GDPR, we consider:

any external and internal issues that are relevant to our purpose and that affect our ability to achieve the intended outcomes of its PIMS/ISP;
specific needs and expectations of interested parties that are relevant to the implementation of the PIMS/ISP;
organizational objectives and obligations;
the organisation’s acceptable level of risk; and
any applicable statutory, regulatory, or contractual obligations.

3.5. The PIMS is documented within the ISP system, maintained in our Intranet. Our Company’s objectives for compliance with the UK-GDPR are consistent with this Policy, measurable, take into account UK-GDPR privacy requirements and the results from risk assessments and risk treatments, monitored, communicated and updated as appropriate.

4. Responsibilities & Roles under the General Data Protection Regulation

4.1. We are a data controller for staff and marketing data and a data processor for client data under the UK-GDPR.

4.2. All those in managerial or supervisory roles throughout our Organisation are responsible for developing and encouraging good information handling practices within our Company.

4.3. Main Portfolio LTD and our Board of Directors for the management of personal data within our Company and for ensuring that compliance with data protection legislation and good practice can be demonstrated. This accountability includes development and implementation of the UK-GDPR as required by this Policy, and security and risk management in relation to compliance with the Policy.

4.4. The Legal Compliance Department has been appointed to take responsibility for our Company’s compliance with this Policy on a day-to-day basis and has direct responsibility for ensuring that our Company complies with the UK-GDPR.

4.5. The Legal Compliance Department shall have specific responsibilities in respect of procedures such as the Subject Access Request Procedure and is the first point of call for Employees/Staff seeking clarification on any aspect of data protection compliance.

4.6. Compliance with data protection legislation is a responsibility of and obligation for all our Employees/Staff who process personal data.

4.7. Our Company’s Training Policy sets out specific UK-GDPR training and awareness requirements in relation to specific roles of our Employees/Staff generally.

4.8. Our Employees/Staff are responsible for ensuring that any personal data about them and supplied by them to our Company is accurate and up-to-date.

5. Data Protection Principles

5.1. All processing of personal data must be conducted in accordance with the data protection principles as set out in Articles 5 and 6 of the UK-GDPR. Our policies and procedures are designed to ensure compliance with the principles.

5.2. Personal data must be processed lawfully, fairly & transparently

Lawfully – you must identify a lawful basis before you can process personal data. These are often referred to as the “conditions for processing”, for example, consent.
Fairly – in order for processing to be fair, the data controller has to make sure that personal data are handled in ways that the data subject would reasonably expect and not use it in ways that have unjustified adverse effects on it.
Transparently – Transparent processing is about being clear, open and honest with people from the start about who you are, and how and why you use their personal data. We ensure that we tell individuals about our processing in a way that is easily accessible and easy to understand. You must use clear and plain language.

5.3. The specific information that must be provided to the data subject must, as a minimum, include:

the identity and the contact details of the controller and, if any, of the controller’s representative;
the contact details of the DPO (if a DPO is appointed) or the contact details of the relevant Department to appointed by the Organisation to responsible to establish GDPR compliance);
the purposes of the processing for which the personal data are intended as well as the legal basis for the processing;
the period for which the personal data will be stored;
the existence of the rights to request access, rectification, erasure or to object to the processing, and the conditions (or lack of) relating to exercising these rights, such as whether the lawfulness of previous processing will be affected;
the categories of personal data concerned;
any further information necessary to guarantee fair

5.4. Personal data can only be collected for specific, explicit and legitimate purposes

Personal Data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
The Privacy Procedure sets out the relevant procedures.

5.5. Personal data must be adequate, relevant and limited to what is necessary for processing

The Legal Compliance Department is responsible for ensuring that we do not collect information that is not strictly necessary for the purpose for which it is obtained.
All data collection forms (electronic or paper-based), including data collection requirements in new information systems, must include a fair processing statement or a link to privacy statement and approved by the Legal Compliance Department.
The Legal Compliance Department will ensure that, on an annual basis all data collection methods are reviewed by internal audit to ensure that collected data continues to be adequate, relevant and not excessive.

5.6. Personal data must be accurate and kept up to date with every effort to erase or rectify without delay

Data that is stored by the data controller must be reviewed and updated as necessary. No data should be kept unless it is reasonable to assume that it is accurate. The Legal Compliance Department is responsible for ensuring that all staff are trained in the importance of collecting accurate data and maintaining it.
Employees/Staff/clients/contractors and third-party providers should be required to notify the Company of any changes in circumstance to enable personal records to be updated accordingly. It is the responsibility of the Company to ensure that any notification regarding change of circumstances is recorded and acted upon.
The Legal Compliance Department is responsible for ensuring that appropriate procedures and policies are in place to keep personal data accurate and up to date, taking into account the volume of data collected, the speed with which it might change and any other relevant factors.
On at least an annual basis, the Legal Compliance Department will review the retention dates of all the personal data processed by our Company, by reference to the data inventory, and will identify any data that is no longer required in the context of the registered purpose. This data will be securely deleted/destroyed in line with the Information Disposal Policy.
The Legal Compliance Department is responsible for responding to requests for rectification from data subjects within one month. This can be extended to a further two months for complex requests. If our Company decides not to comply with the request, the Legal Compliance Department must respond to the data subject to explain its reasoning and inform them of their right to complain to the supervisory authority and seek judicial remedy.

5.7. Personal data must be kept in a form such that the data subject can be identified only as long as is necessary for processing.

Where personal data is retained beyond the processing date, it will be minimised/ encrypted/ pseudonymised in order to protect the identity of the data subject in the event of a data breach. Personal data will be retained in line with the ISP and, once its retention date is passed, it must be securely destroyed as set out in this procedure.
The Legal Compliance Department must specifically approve any data retention that exceeds the retention periods defined in the ISP and must ensure that the justification is clearly identified and in line with the requirements of the data protection legislation. This approval must be written.

5.8. Personal data must be processed in a manner that ensures the appropriate security

The Legal Compliance Department will carry out a Data Protection Risk Assessment (DPIA) taking into account all the circumstances of our Company’s controlling or processing operations.
In determining appropriateness, the Legal Compliance Department should also consider the extent of possible damage or loss that might be caused to individuals (e.g., staff or customers) if a security breach occurs, the effect of any security breach on the Company itself, and any likely reputational damage including the possible loss of customer trust.

5.9. When assessing appropriate technical measures, the Legal Compliance Department shall consider the following:

Password Protection
Automatic locking of idle terminals;
Removal of access rights for USB and other memory media;
Virus checking software and firewalls;
Role-based access rights including those assigned to temporary staff;
Encryption of devices that leave the organisations premises such as laptops;
Security of local and wide area networks;
Privacy enhancing technologies such as pseudonymisation and anonymisation;
Identifying appropriate international security standards relevant to the Company’s procedures.

5.10. When assessing appropriate organisational measures, the Legal Compliance Department shall consider the following:

The appropriate training levels throughout our Company;
Measures that consider the reliability of employees (such as references etc.);
The inclusion of data protection clause in employment contracts;
Identification of disciplinary action measures for data breaches;
Monitoring of staff for compliance with relevant security standards;
Physical access controls to electronic and paper-based records;
Adoption of a Clear Desk Policy;
Storing of paper-based data in lockable fire-proof cabinets;
Restricting the use of portable electronic devices outside of the workplace;
Restricting the use of employees’ own personal devices being used in the workplace;
Adopting clear rules about passwords;
Making regular backups of personal data and storing the media off-site.

5.11. These controls have been selected on the basis of identified risks to personal data, and the potential for damage or distress to individuals whose data is being processed. Our Company’s compliance with this principle is contained in its PIMS, which has been developed in line with the ISP.

5.12. The controller must be able to demonstrate compliance with the UK-GDPR’s other principles (accountability)

The UK-GDPR includes provisions that promote accountability and governance. These complement the UK-GDPR’s transparency requirements. The accountability principle in Article 5(2) requires you to demonstrate that you comply with the principles and states explicitly that this is your responsibility.
Our Company will demonstrate compliance with the data protection principles by implementing data protection policies, adhering to codes of conduct, implementing technical and organisational measures, as well as adopting techniques such as data protection by design, DPIAs, breach notification procedures and incident response plans.

6. Personal Data Individuals’ Rights

6.1. Each individual shall have the following rights regarding data processing, and the data that is recorded about them:

To make access requests regarding the nature of information held and to whom it has been disclosed.
To prevent processing likely to cause damage or distress.
To prevent processing for purposes of direct marketing.
To be informed about the mechanics of automated decision-taking process that will significantly affect them.
To not have significant decisions that will affect them taken solely by automated process.
To sue for compensation if they suffer damage by any contravention of the UK-GDPR.
To take action to rectify, block, erase or destroy inaccurate data.
To request the supervisory authority to assess whether any provision of the UK-GDPR has been contravened.
To have personal data provided to them in a structured, commonly used and machine-readable format, and the right to have that data transmitted to another controller.
To object to any automated profiling that is occurring without

6.2. Our Company ensures that individuals may exercise these rights by making data access requests as described in the Acceptable Use Agreement, which shall include the Subject Access Request Procedure. This procedure also describes how our Company will ensure that its response to the data access request complies with the requirements of the UK-GDPR.

6.3. Individuals shall also have the right to complain to the Company related to the processing of their personal data, handling of a request from a data subject and appeals from a data subject on how complaints have been handled in line with the Complaints Procedure.

7. Consent

7.1. Our Company understands “consent” to mean that it has been explicitly and freely given, and a specific, informed and unambiguous indication of the data subject’s wishes that, by statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her. The data subject can withdraw their consent at any time.

7.2. Our Company understands “consent” to mean that the data subject has been fully informed of the intended processing and has signified their agreement, while in a fit state of mind to do so and without pressure being exerted upon them. Consent obtained under duress or on the basis of misleading information will not be a valid basis for processing.

7.3. There must be some active communication between the parties to demonstrate active consent. Consent cannot be inferred from non-response to a communication. The Controller must be able to demonstrate that consent was obtained for the processing operation.

7.4. For sensitive data, explicit written consent of individuals must be obtained unless an alternative legitimate basis for processing exists.

7.5. In most instances, consent to process personal and sensitive data is obtained routinely by the Company using standard consent documents e.g., when a new client signs a contract, or during induction for participants on programmes.

7.6. Where our Company provides online services to children, parental or custodial authorisation must be obtained. This requirement applies to children under the age of 13. Our Company does not routinely process data in this category.

8.Security of Data

8.1. All Employees/Staff are responsible for ensuring that any personal data that our Company holds and for which they are responsible, is kept securely and is not under any conditions disclosed to any third party unless that third party has been specifically authorised by our Company to receive that information and has entered into a confidentiality agreement.

8.2. All personal data should be accessible only to those who need to use it, and access may only be granted in line with the Company’s Policies.

8.3. Care must be taken to ensure that PC screens and terminals are not visible except to authorised Employees/Staff of the Company. All Employees/Staff are required to enter into an Acceptable Use Agreement before they are given access to organisational information of any sort, which details rules on screen time-outs.

8.4. Manual records may not be left where they can be accessed by unauthorised personnel and may not be removed from business premises without explicit written authorisation. As soon as manual records are no longer required for day-to-day client support, they must be removed from secure archiving.

8.5. Personal data may only be deleted or disposed of in line with the Information Retention procedure. Manual records that have reached their retention date are to be shredded and disposed of as “confidential waste”. Hard drives of redundant PCs are to be removed and immediately destroyed.

9. Disclosure of Data

9.1. The Company must ensure that personal data is not disclosed to unauthorised third parties which includes family members, friends, government bodies, and in certain circumstances, the Police. All Employees/Staff should exercise caution when asked to disclose personal data held on another individual to a third party.

9.2. It is important to bear in mind whether or not disclosure of the information is relevant to, and necessary for the conduct of our Company’s business.

10. Retention & Disposal of Data

10.1. The Company shall not keep personal data in a form that permits identification of data subjects for longer a period than it is necessary, in relation to the purpose(s) for which the data was originally collected.

10.2. The Company may store data for longer periods if the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, subject to the implementation of appropriate technical and organisational measures to safeguard the rights and freedoms of the data subject.

10.3. The retention period for each category of personal data will be set out in the Information Retention procedure along with the criteria used to determine this period including any statutory obligations the Company has to retain the data.

10.4. The Company’s information retention and information disposal procedures apply in all cases.

10.5. Personal data must be disposed of securely in accordance with the sixth principle of the UK-GDPR. Any disposal of data will be done in accordance with the secure disposal procedure.

11. Data Transfers

11.1. On 28 June 2021 the EU Commission adopted decisions on the UK’s adequacy under the EU’s General Data Protection Regulation (EU GDPR) and Law Enforcement Directive (LED). In both cases, the European Commission has found the UK to be adequate. This means that most data can continue to flow from the EU and the EEA without the need for additional safeguards.

11.2. All exports of data from the UK and the European Economic Area (EEA) to non-European Economic Area countries (referred to in the UK-GDPR as “third countries”) are unlawful unless there is an appropriate “level of protection for the fundamental rights of the data subjects”.

11.3. The broader area of the EEA is granted “adequacy” on the basis that all such countries are signatories to the GDPR. The non-EU EEA member countries (Liechtenstein, Norway and Iceland) apply EU regulations through a Joint Committee Decision.

11.4. Binding Corporate Rules:
The Company may adopt approved binding corporate rules for the transfer of data outside the EU. This requires submission to the relevant supervisory authority for approval of the rules that the Company is seeking to rely upon.

11.5. Model Contract Clauses:
The Company may adopt approved model contract clauses for the transfer of data outside of the UK and the EEA. If the Company adopts the model contract clauses approved by the relevant supervisory authority there is an automatic recognition of adequacy.

11.6. Exceptions:
In the absence of an adequacy decision, Privacy Shield membership, binding corporate rules and/or model contract clauses, a transfer of personal data to a third country or international organisation shall only take place on one of the following conditions:

the individual has explicitly consented to the proposed transfer, after having been informed of the possible risks of such transfers for the data subject due to the absence of an adequacy decision and appropriate safeguards;
the transfer is necessary for the performance of a contract between the individual and the controller or the implementation of pre-contractual measures taken at the data subject’s request;
the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the data subject between the controller and another natural or legal person;
the transfer is necessary for important reasons of public interest;
the transfer is necessary for the establishment, exercise or defence of legal claims; and/or
the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent.

12. Data Inventory

12.1. The Company has established a Data Inventory and Data Flow process as part of its approach to address risks and opportunities throughout its UK-GDPR compliance project. The Company’s Data Inventory and Data Flow determines:

business processes that use personal data;
source of personal data;
volume of data subjects;
description of each item of personal data;
processing activity;
maintains the inventory of data categories of personal data processed;
documents the purpose(s) for which each category of personal data is used;
recipients, and potential recipients, of the personal data;
the role of the Company throughout the data flow;
key systems and repositories;
any data transfers; and
all retention and disposal requirements.

12.2. Our Company is aware of any risks associated with the processing of particular types of personal data:

The Company assesses the level of risk to individuals associated with the processing of their personal data. Data Protection Impact Assessments (DPIAs) are carried out in relation to the processing of personal data by the Company, and in relation to processing undertaken by other organisations on behalf of the Company.
The Company shall manage any risks identified by the risk assessment in order to reduce the likelihood of a non-conformance with this Policy.
Where a type of processing, in particular using new technologies and taking into account the nature, scope, context and purposes of the processing is likely to result in a high risk to the rights and freedoms of natural persons, our Company shall, prior to the processing, carry out a DPIA of the impact of the envisaged processing operations on the protection of personal data. A single DPIA may address a set of similar processing operations that present similar high risks.
Where, as a result of a DPIA it is clear that the Company is about to commence processing of personal data that could cause damage the Company and/or distress to the data subjects, the decision as to whether or not the Company may proceed must be escalated for review to the Legal Compliance Department.
The Legal Compliance Department shall, if there are significant concerns, either as to the potential damage or distress, or the quantity of data concerned, escalate the matter to the supervisory
Appropriate controls will be selected, as appropriate and applied to reduce the level of risk associated with processing individual data to an acceptable level, by reference to the Company’s documented risk acceptance criteria and the requirements of the UK-GDPR.

Data Retention Policy

1. Purpose

1.1. The purpose of this Policy is to detail procedures for the retention and disposal of information and personal data. This Policy refers to both hard and soft copy documents, unless specifically stated otherwise.

2. Scope

2.1. This Policy covers all data collected by and stored on the Company owned or leased systems and media, regardless of location. It applies to both data collected and held electronically (including photographs, video and audio recordings) and data that is collected and held as hard copy or paper files.

2.2. The need to retain certain information may be mandated by federal or local law, federal regulations and legitimate business purposes, as well as the EU General Data Protection Regulation (GDPR).

3. Reasons for Data Retention

3.1. The Company retains only that data that is necessary to effectively conduct its program activities, fulfil its mission and comply with applicable laws and regulations. Reasons for data retention include:

Providing an ongoing service to the data subject (e.g. sending a newsletter, publication or ongoing program update to an individual, ongoing training or participation in the Company’s programs, processing of employee payroll and other benefits).
Compliance with applicable laws and regulations associated with financial and programmatic reporting by the Company to its funding agencies and other donors.
Compliance with applicable labour, tax and immigration laws.
Other regulatory requirements.
Security incident or other investigation.
Intellectual property preservation.
Litigation

4. Review

4.1. Each department processing personal data must go through its ‘closed records’ at least every 6 months to determine whether the records should be destroyed, retained for a further period or transferred to an archive for permanent preservation.

5. Retention Period for Paper Records

5.1 Records should only be kept for as long as they are needed to meet the operational needs of the business, and to fulfil legal and regulatory requirements.

5.2. If any (or more) below applies then you must determine the length the records should be kept for, otherwise the records must be destroyed in line with this Policy.

Is it necessary as a source of information for operations at Main Portfolio LTD?		Is it necessary as evidence of business activities and decisions?		Is it necessary because of legal or regulatory retention requirements?

6. Destruction of Records

6.1. No destruction of a record should take place without assurance that:

The record is no longer required by any part of the business;
No work is outstanding by any part of the business;
No litigation or investigation is current or pending which affects the record;
There are no current to pending Subject Access Requests which affect the record.

Records should be destroyed in the following ways:

Non-sensitive information

Information/records that are clearly in the ‘public domain’ can be placed in a normal recycling rubbish bin

Confidential information

Must be cross cut shredded and placed in paper rubbish sacks for collection by an approved disposal firm.

Electronic devices containing information (must be overseen by the Head of IT)

Option 1 – ‘Factory’ system restore

Option 2 – destroy all information using

specialised software programs.

Main Portfolio LTD may work with approved contractors to recycle redundant
IT equipment and must securely sanitise all hard drives. A certificate confirming the complete destruction of records must be provided by
the contractors.

Equipment must be kept in a secure location until collected.

Managers of each department must ensure locally stored confidential information is removed as appropriate before a device is reassigned
to another person in their team.

7. Audit Trail

7.1. There is no requirement to document the disposal of records which have been listed on the records retention schedule.

7.2. If records are disposed of earlier or kept for longer than listed on the records retention schedule, then they must be recorded for audit purposes.

7.3. This will provide an audit trail for any inspections conducted by the Information Commissioner Office and will aid in addressing Subject Access Request, where we no longer hold the material.

Disposal Schedule (Should you become aware of any records missing from the schedule, please notify the Company so that they may be added at the next opportunity).
Heading	Description	Retention Period	Comments
Payroll	Employee pay records	for the period of employment plus six 6 years after the employee leaves the organisation
	Salary records	for the period of employment plus six 6 years after the employee leaves the organisation
	Copy of payroll sheets	for the period of employment plus six 6 years after the employee leaves the organisation
Employee Files	Paper and hardcopy employee files	for the period of employment plus six 6 years after the employee leaves the organisation	Limitations Act 1980
Income Tax Records and Wages	Income Tax and NI returns, Income tax records and correspondence with the Inland Revenue	At least 3 years after the end of the financial year to which they relate.	The Income Tax (Employments) Regulations 1993
Income Tax Records and Wages	Wages/salary records (including overtime, bonuses, expenses)	for the period of employment plus six 6 years after the employee leaves the organisation	Taxes Management Act 1970
Income Tax Records and Wages	National minimum wage records	3 years after the end of the pay reference period following the one that the records cover	National Minimum Wage Act 1998
Pensions and Retirement	Autoenrollment member and scheme details	for the period of employment plus six 6 years after the employee leaves the organisation	Autoenrollment regulations
Sickness records	Statutory Maternity Pay records, calculations, certificates (Mat B1s) or other medical evidence	3 years after the end of the tax year in which the maternity period ends	The Statutory Maternity Pay (General) Regulations1986
Sickness records	Statutory Sick Pay records, calculations, certificates, self- certificates	3 years after the end of the tax year to which they relate	The Statutory Sick Pay (General) Regulations 1982
Employee Files – General Exceptions	Records relating to working time	2 years from the date on which they were made	The Working Time Regulations 1998
Employee Files – General Exceptions	Accident books, accident records/report	3 years after the date of the last entry	The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995.

WHERE TO GO FOR ADVICE AND QUESTIONS

Questions, comments, complaints and requests regarding this Policy are welcomed and should be addressed to our office address, K2 Tower 60 Bond Street, Silvester St Entrance, Hull, England, HU1 3EN or to our Legal Compliance Department at legal@mainportfolio.co.uk.

In addition, please do not hesitate to contact us if you suspect any privacy or security breaches.

OTHER RELEVANT POLICIES

This Policy supplements and should be read in conjunction with our other policies and procedures in force from time to time, including without limitation our:

Data Protection Policy;
Data Breach Management Policy;
Information Security and Risk Management Policies;
IT data related policies, which are available on the Portal; and
Code of Ethics.

Data Breach Management Policy

All users need to read, understand, and comply with this Policy

1. Introduction

1.1. The Company collects, holds, processes and shares large amounts of personal data and has an obligation to ensure that it is kept secure and appropriately protected.

1.2. Information is a key Company asset and as such ensuring the continued confidentiality, integrity and availability is essential to support the Company operations. The Company is also required to operate within the law, specifically the expectations set out in the Data Protection Act 1998 (DPA) and the General Data Protection Regulation (UK-GDPR).

1.3. Data security breaches are increasingly common occurrences whether these are caused through human or technical error or via malicious intent. As technology trends change and the volume of data and information created grows, there are more emerging ways by which data can be breached. The Company needs to have in place a robust and systematic process for responding to any reported potential data security breach, to ensure it can act responsibly, protect individual’s data, Company information assets and reputation as far as possible.

1.4. Data security breaches will vary in impact and risk depending on the content and quantity of data involved, the circumstances of the loss and the speed of response to the incident. By managing all perceived data security breaches in a timely manner, it may be possible to contain and recover the data before it an actual breach occurs, reducing the risks and impact to both individuals and the Company. Breaches can result in fines for loss of personal information and significant reputational damage, and may require substantial time and resources to rectify the breach. As of May 2018, the GDPR replaced the DPA with fine limits increasing up to €20 million for a breach. Breach reporting within 72 hours of identifying a breach is mandatory under the GDPR, with fines of up to €10 million for failing to report a breach.

2. Purpose

2.1. The purpose of this procedure is to ensure that:

personal data breaches are detected, reported, categorised and monitored consistently;
incidents are assessed and responded to appropriately without undue delay;
decisive action is taken to reduce the impact of a breach;
improvements are implemented and communicated to prevent recurrence or future incidents;
certain personal data breaches are reported to the Information Commissioner’s Office (ICO) within 72 hours, where required.

2.2. This document sets out the procedure to be followed to ensure a consistent and effective approach in managing personal data security breaches across the Company.

3. Scope

3.1. This procedure applies to all staff, partner organisations and partner staff, suppliers, contractors, consultants, representatives and agents that work for or process, access, use or manage personal data on behalf of the Company.

3.2. This procedure relates to all personal and special category (‘sensitive’) information handled, stored, processed or shared by the Company whether organised and stored in physical or IT based record systems.

4. Definition

4.1. What is a data security breach?

A personal data security breach means “a breach of security leading to the loss, unauthorised destruction, alteration or disclosure of, or access to, personal data transmitted, stored or otherwise processed”.
A data security breach is considered to be any loss of, or unauthorised access to, Company data, normally involving Personal or Confidential information including intellectual property.
Data security breaches include the loss, modification, or theft of data or equipment on which data is stored, inappropriate access controls allowing unauthorised use, human error (e.g. information sent to the incorrect recipient), hacking attacks and ‘blagging’ where information is obtained by deception.
A personal data breach in the context of this procedure is an event or action that has affected the confidentiality, integrity or availability of personal data, either accidentally or deliberately, that results in its security being compromised, and has caused or has the potential to cause damage to the Company and/or the individuals to whom the information relates to.

4.2. What is a data security incident?

A data security incident is where there is the risk of a breach but a loss or unauthorised access has not actually occurred.
It is not always clear if an incident has resulted in a breach; by reporting all perceived data breaches quickly, steps can be taken to investigate, secure the information and prevent the incident becoming an actual breach (e.g. by reporting an email IT can remove the email before it has been read and therefore the data has been contained and not been seen by the incorrect recipient).
For the purposes of this policy, data security breaches include both confirmed and suspected incidents and breaches.

4.3. A data breach incident includes, but is not limited to:

Devices containing personal data being lost or stolen (e.g. laptop, USB stick, iPad/tablet device or paper record);
Access by an unauthorised third party or unlawful disclosure of personal data to a third party Deliberate or accidental action (or inaction) by a data controller or processor;
Sending personal data to an incorrect recipient;
Alteration of personal data without permission;
Loss of availability of personal data;
Data input error / human error;
Non-secure disposal of hardware or paperwork containing personal data;
Inappropriate access/sharing allowing unauthorised use of, access to or modification of data or information systems;
‘Blagging’ offences where information is obtained by deceiving the organisation who holds it.

5. Reporting an Incident

5.1. The Company adopts a culture in which data protection breaches are reported. Any staff, contractor, partnership organisation, partner staff or individual that processes, accesses, uses or manages personal data on behalf of the Company is responsible for reporting information security incidents and data breaches immediately or within 24 hours of being aware of a breach to their supervisor or to the Legal Compliance Department at legal@mainportfolio.co.uk, who will investigate the potential breach.

5.2. If the breach occurs or is discovered outside normal working hours, it must be reported as soon as is practicable.

5.3. A Data Breach Report Form (see Appendix 1 ) should be completed as part of the reporting process and emailed it to their supervisor or to the Legal Compliance Department at legal@mainportfolio.co.uk. The report will include full and accurate details of the incident, when the breach occurred (dates and times), who is reporting it, the nature of the information and how many individuals are involved.

6. Containment & Recovery

6.1. The Legal Compliance Department in liaison with the respective supervisor and/or Information Security Officer, will determine if the breach is still occurring. If so, the appropriate steps will be taken immediately to minimise the effect of the breach.

6.2. An initial assessment will be made to establish the severity of the breach, who will take the lead as designated Investigating Officer to investigate the breach (this will depend on the nature of the breach) and determine the suitable course of action to be taken to ensure a resolution to the incident.

6.3. The Investigating Officer will establish whether there is anything that can be done to recover any losses and limit the damage the breach could cause.

6.4. The Investigating Officer will establish who may need to be notified as part of the initial containment.

6.5. Advice from experts across the Company such as IT, HR and legal and in some cases contact with external third parties may be sought in resolving the incident promptly.

7.Investigation & Assessing the Risks

7.1. An investigation will be undertaken by the Investigating Officer immediately and wherever possible within 24 hours of the breach being discovered/reported.

7.2. The Investigating Officer will investigate the breach and assess the risks associated with it, for example, the potential adverse consequences for individuals, how likely they are to happen and how serious or substantial they are.

7.3. The level of risk associated with a breach can vary depending on the type of data and its sensitivity.

7.4. The investigation will need to consider the following:

What type of data is involved?
How sensitive is the data?
Where data has been lost or stolen are there any protections in place such as encryption?
What has happened to the data? Has it been lost or stolen?
Could the data be put to any illegal or inappropriate use?
Could it be used for purposes which are harmful to the individuals to whom the data relates?
How many individuals’ personal data has been affected by the breach? Who are the individuals whose data has been breached?
What harm can come to those individuals?
Are there risks to physical safety or reputation, of financial loss or a combination of these and other aspects of their life?
Are there wider consequences to consider?

8. Notification of Breaches

8.1. The Investigating Officer in consultation with the Legal Compliance Department and/or the Information Security Officer, will determine who needs to be notified of the breach.

8.2. Any notification must be agreed by the management.

8.3. Every incident will be assessed on a case-by-case basis.

8.4. Not every incident merit notification and over notification may cause disproportionate enquiries and work.

8.5. The following will need to be considered:

Are there any legal/contractual notification requirements?
Can notification help the individual? Could they take steps to act on the information to protect themselves?
Would notification help prevent the unauthorised or unlawful use of personal data?
Can notification help the Company meet its obligations under the data protection principles?
Is there a large number of people that are affected? Are there serious consequences?
Should the ICO be notified of the personal data breach? The ICO must be notified where there is likely to be a risk to people’s rights and freedoms.
If so, notification shall be within 72 hours with details of:
1. a description of the nature of the personal data breach including, where possible:
  - the categories and approximate number of individuals concerned; and
  - the categories and approximate number of personal data records concerned.
2. the name and contact details of the data protection officer or other contact point where more information can be obtained;
3. a description of the likely consequences of the personal data breach;
4. details of the security measures and procedures in place at the time the breach occurred; and
5. a description of the measures taken, or proposed to be taken, to deal with the personal data breach, including, where appropriate, the measures taken to mitigate any possible adverse effects.

8.6. If a breach is likely to result in a high risk to the rights and freedoms of individuals, notification to the individuals whose personal data has been affected by the incident must be without undue delay describing:

the nature of the personal data breach;
the name and contact details of the data protection officer or other contact point where more information can be obtained;
a description of the likely consequences of the personal data breach; and
a description of the measures taken, or proposed to be taken, to deal with the personal data breach and including, where appropriate, of the measures taken to mitigate any possible adverse effects including what action the individual(s) can take to protect themselves.
The following factors to consider include:
Sensitivity of information;
Volume of information;
Likelihood of unauthorised use;
Impact on individual(s);
Feasibility of contacting individuals.

8.7. If the Company decides not to notify the individuals affected, it will still need to notify the ICO unless it can demonstrate that the breach is unlikely to result in a risk to rights and freedoms.

8.8. The Investigating Officer and/or Legal Compliance Department must consider notifying third parties such as the police, insurers, professional bodies, bank or credit card companies who can help reduce the risk of financial loss to individuals. This would be appropriate where illegal activity is known or is believed to have occurred, or where there is a risk that illegal activity might occur in the future.

8.9. The Investigating Officer and/or Legal Compliance Department will consider whether the Marketing and Communications Team should be informed regarding a press release and to be ready to handle any incoming press enquiries.

8.10. All personal data breaches and actions will be recorded by the Legal Compliance Department regardless of whether or not they need to be reported to the ICO.

9. Evaluation & Response

9.1. Data protection breach management is a process of continual review. Once the initial incident is contained, the Investigating Officer will carry out a full review of the causes of the breach; the effectiveness of the response(s) and whether any changes to systems, policies and procedures should be undertaken.

9.2. Existing controls will be reviewed to determine their adequacy, and whether any corrective action should be taken to minimise the risk of similar incidents occurring.

9.3 The review will consider:

Where and how personal data is held/ stored;
Where the biggest risks lie and identify any further potential weak points within its existing security measures;
Whether methods of transmission are secure;
Sharing minimum amount of data necessary;
Staff awareness.

9.4. Regardless of the type and severity of incident, there will always be recommendations to be made even if it is only to reinforce existing procedures.

9.5. All recommendations will be assigned an owner and have a timescale by when they should be implemented which has a dual purpose. The first is to ensure that the Company puts in place whatever measures have been identified and that there is an individual that can report back to the Investigating Officer on progress. The second is that where incidents are reported to the ICO, the Company can demonstrate that the measures have either been put in place or that there is a documented plan to do so.

9.6. Identifying recommendations is more than just damage control. The knowledge of what has happened together with the impact is a fundamental part of learning and continual improvement which can then be disseminated throughout the Company.

Revised: 10/2024

Information Security Policy

1. Purpose

1.1. This high-level Information Security Policy sits alongside the “Information Risk Management Policy” and “Data Protection Policy”.

1.2. This Policy provides a high-level outline of, and justification for, the Company’s risk-based information security controls.

2. Legal Basis

2.1. Information that is collected, analysed, stored, communicated and reported upon may be subject to theft, misuse, loss and corruption.

2.2. Information may be put at risk by reduced awareness and/or training, and the breach of security controls.

2.3. Information security incidents can give rise to embarrassment, financial loss, non-compliance with standards and legislation, as well as possible judgements being made against the Company.

3. Objectives

3.1. Our Company’s security objectives are key to improving Employees/Users awareness and knowledge of security best practices.

3.2. We focus on:

information risks being identified, managed and treated according to a fixed risk tolerance;
authorised Employees/Users’ access and share information securely in order to perform their duties and roles;
physical, procedural and technical controls are balanced with Employee/User experience and security;
contractual and legal obligations relating to information security being met at all times;
all business and administrative activities always consider information security matters;
individuals accessing information are aware of their information security responsibilities;
incidents affecting information assets are quickly and effectively resolved and work as a motive to improve our security controls.

4. Scope

4.1. The Information Security Policy and its supporting controls, processes and procedures apply to all information used and processed by the Company, in all formats. This includes information processed by other organisations in their dealings with the Company.

4.2. The Information Security Policy and its supporting controls, processes and procedures apply to all individuals who have access to the Company’s information, technologies and apps, including external parties that provide information processing services to the Company.

5. Compliance Monitoring

Compliance with the controls in this Policy shall be monitored by the Information Security Team, and reported to the Information Security Officer.

6. Review

A review of this Policy is undertaken by the Company’s Legal Team on an annual basis or more frequently if required.

7. Policy Statement

7.1. It is the Company’s policy to ensure that information is protected from a loss of:

Confidentiality: information will be lawfully accessible only to authorised individuals.
Integrity: the accuracy and completeness of information will be maintained.
Availability: information will be accessible to authorised Employees/Users and processed only as required by law or lawful purpose.

7.2. The Company will implement an Information Security Management System based on certified standards as required by law. The Company shall be mindful of the approaches adopted by its stakeholders, including third partners.

8. The Company’s risk-based controls

8.1. Information Security Policies

A set of lower-level controls, processes and procedures for information security are defined, in support of the high-level Information Security Policy and its stated objectives. This suite of supporting documentation as approved by the Company, shall be published and communicated to Company’s Employees/Users and relevant external parties.

8.2. Organisation of Information Security

The Company defines and implements suitable governance arrangements for the management of information security. This includes identification and allocation of security responsibilities, to initiate and control the implementation and operation of information security within the Company.

The Company has appointed Information Security Officer and take accountability for information risk.

8.3. Human Resources Security

The Company’s security policies and expectations for acceptable use will be communicated to all Employees/Users to ensure that they understand their information security obligations and responsibilities. Information security training will be made available to all Employees/Users. Poor or inappropriate behaviour will be addressed.

Where practical, security responsibilities will be included in role descriptions, person specifications and personal development plans.

8.4. Information Assets management

All information assets will be documented and accounted for.

This includes:

Information: any information that can be used to identify a person, including sensitive information;
Software;
Electronic information processing equipment;
Service benefits;
Human

Owners will be identified for all information assets and will be responsible for the maintenance and protection of their assets.

All information assets are classified according to their legal requirements, business value, criticality and sensitivity. Classification indicates appropriate handling requirements. All information assets will have a defined retention and disposal schedule.

8.5. Access Control

Access to all information will be controlled and will be driven by business requirements. Access will be granted or arrangements made for Employees/Users according to their role and the classification of information, only to a level that will allow them to carry out their duties.

A formal user registration and de-registration procedure will be maintained for access to all information systems and services. This will include mandatory authentication methods based on the sensitivity of the information being accessed, and will include consideration of multiple factors as appropriate.

Specific controls will be implemented for users with elevated privileges, to reduce the risk of negligent or deliberate system misuse. The separation of duties will be implemented, where practical.

8.6. Cryptography

The Company will provide guidance and tools to ensure proper and effective use of cryptography to protect the confidentiality, authenticity and integrity of information and systems.

8.7. Physical & Environmental Security

Information Processing Facilities (IPF) are housed in secure areas (sites where sensitive information is handled or housed) physically protected from unauthorised access, damage and interference by defined security perimeters. Layered internal and external security controls are in place to deter or prevent unauthorised access and protect assets. This includes those that are critical or sensitive, against forcible or hidden attacks.

8.8. Operations Security

The Company ensures the correct and secure operations of information processing systems.

This includes:

documented operating procedures;
use of formal change and capacity management;
controls against malware;
defined use of logging;
vulnerability management.

8.9. Communications Security

The Company maintains network security controls to ensure the protection of information within its networks. The Company also provides the tools and guidance to ensure the secure transfer of information both within its networks as well as with external entities. This is done line with the classification and handling requirements associated with each particular type/category of information.

8.10. System Acquisition, Development & Maintenance

Information security requirements are defined during the development of business requirements for new information systems or changes to existing information systems.

Controls to reduce any risks identified are implemented where appropriate.

Systems development are always subject to change control and separation of test, development and operational environments.

8.11. Supplier Relationships

The Company’s information security requirements will be considered when establishing relationships with suppliers, to ensure that assets accessible to suppliers are protected.

Suppliers’ activity is monitored and audited according to the value of the assets and the associated risks.

8.12. Information Security Incident Management

Guidance will be available on what constitutes an information security incident and how this should be reported. Actual or suspected breaches of information security must be reported and shall be investigated. The appropriate action to correct the breach will be taken, and any learning built into controls.

8.13. Information Security Aspects of Business Continuity Management

The Company has implemented arrangements to protect critical business processes from the effects of major failures of information systems or disasters. This is to ensure their timely recovery in line with documented business needs. This will include appropriate backup routines and built-in resilience.

Business continuity must be maintained and tested in support of this policy.

Business impact analysis is undertaken, detailing the consequences of:

disasters;
security failure(s);
loss of service;
lack of service availability.

8.14. Third-Party Management

Third-party vendors, suppliers and/or contractors shall be required to adhere to the same information security standards as the Company and this Policy. Contracts with third parties shall include provisions for data protection and security audits.

8.15. Compliance

The design, operation, use and management of information systems must comply with all statutory, regulatory and contractual security requirements.

Currently this includes:

data protection legislation;
the payment card industry standard (PCI-DSS);
the government’s Prevent strategy;
the Company’s contractual commitments;
the Company’s Policies and Procedures.

The Company uses a combination of internal and external audits to demonstrate compliance against chosen standards and best practice, including against internal policies and procedures.

This includes:

IT health checks;
Gap analyses against documented standards;
Internal checks on staff compliance;
Returns from Information Asset Owners.

Revised: 11/2024

Information Risk Management Policy

This Policy is to establish guidelines and procedures for managing information risks within our Company

1. Purpose

1.1. Information that is collected, analysed, stored, communicated and reported upon might be subject to theft, misuse, loss and/or corruption.

1.2. However, the implementation of controls to protect information must be based on an assessment of the risk posed to the Company, and must balance the likelihood of negative business impact against the resources required to implement the mitigating controls, and any unintended negative implications of the controls.

1.3. This Policy sets out the principles that the Company uses to identify, assess and manage information risk, in order to support the achievement of its planned objectives, and aligns with the overall Company risk management framework and approach.

1.4. It aims to protect the confidentiality, integrity, and availability of Company’s information assets and ensure compliance with relevant laws and regulations.

1.5. This high-level Information Risk Management Policy sits alongside the Information Security Policy and Data Protection Policy to provide the high-level outline of and justification for the Company’s risk-based information security controls.

2. Objectives

2.1. The Company’s information risk management objectives are focused on:

information risks being identified, managed and treated according to a fixed risk tolerance;
the Information Asset Owner’s consent for physical, procedural and technical controls;
physical, procedural and technical controls are balanced with Employee/User experience and security;
physical, procedural and technical controls are cost-effective and proportionate.

3. Scope

3.1. The Information Risk Management Policy and its supporting controls, processes and procedures apply to all information used at the Company, in all formats. This includes information processed by other organisations in their dealings with the Company.

3.2. The Information Risk Management Policy and its supporting controls, processes and procedures apply to all individuals who have access to Company’s information, technologies and apps, including external parties that provide information processing services to the Company.

4. Roles & Responsibilities

4.1. Clear roles and responsibilities are defined for managing information risks. This includes designating an Information Security Officer responsible for overseeing the implementation and enforcement of this Policy.

4.2. The Information Security Officer:

is responsible for managing the risk assessment process;
maintains an up-to-date risk register;
conducts risk assessments after which action for medium and low risks are recommended;
is responsible for assessing and reviewing high risks;
has visibility of the risk register; and
must also take an active role in identifying and reporting new risks.

5. Compliance & Review

5.1. This Policy is reviewed and updated to ensure compliance with applicable laws, regulations and industry standards by the Information Security Officer on an annual basis or more frequently if required.

6. Policy Statement

6.1. Information risk assessment is a formal and repeatable method for identifying the risks facing an information asset. It is used to determine their impact, and identify and apply controls that are appropriate and justified by the risks.

6.2. It is the Company’s policy to ensure that information is protected from a loss of:

Confidentiality: information will be lawfully accessible only to authorised individuals.
Integrity: the accuracy and completeness of information will be maintained.
Availability: information will be accessible to authorised Employees/Users and processed only as required by law or lawful purpose.

7. Information Classification

7.1. All information assets are classified based on their sensitivity and criticality.

7.2. This classification determines the level of protection required and the access controls to be implemented.

8. Access Control

8.1. Access to information assets is granted based on the principle of least privilege.

8.2. Only authorised individuals are given access, and access rights is regularly reviewed and revoked when no longer required.

9. Incident Response

9.1. An incident response plan is developed and maintained to address security incidents promptly and effectively.

9.2. This plan includes procedures for reporting, investigating, and mitigating incidents, as well as communication and notification requirements.

10. Training & Awareness

10.1. Regular training and awareness programs conducted to train Employees/Users on information risk management best practices, including the proper handling and protection of information assets.

11. Risk Assessment

11.1. Risk assessments must be completed with access to and an understanding of:

the Company’s business processes;
the impact to the Company of risks to business assets;
the technical systems in place supporting the business;
the legislation to which the Company is subject;
up-to-date threat and vulnerability assessments.

11.2.A risk assessment exercise should be completed:

for every new information-processing system;
following modification to systems or processes which could change the threats or vulnerabilities;
following the introduction of a new information asset;
following changes to the threat environment or detection of new vulnerabilities.

12. Threats & Vulnerabilities

12.1. The Company considers all potential threats and vulnerabilities applicable to a particular system, whether natural or human, accidental or malicious.

12.2. Threat and vulnerability information are obtained from specialist security consultancies, local and national law enforcement agencies and security services, and contacts across the sector and region.

12.3. It is the responsibility of the Information Security Officer to maintain channels of communication with appropriate specialist organisations.

13. Risk Register

13.1. The calculations listed in the risk assessment process form the basis of a risk register.

13.2. All risks are assigned an owner and a review date.

13.3. The risk register is held in the Information Security document store, with access controlled by the Information Security Officer.

14. Risk Treatment

14.1. The risk register includes a risk treatment decision. The action must fall into at least one of the following categories:

Pending: where a potential risk has been identified but needs initial investigation.
Tolerate the risk: where the risk is already below the Company’s risk appetite and further treatment is not proportionate.
Treat the risk: where the risk is above the Company’s risk appetite but treatment is proportionate; or where the treatment is so simple and cost effective that it is proportionate to treat the risk even though it falls below the Company’s risk appetite.
Transfer the risk: where the risk cannot be brought below the Company’s risk appetite with proportionate treatment but a cost-effective option is available to transfer the risk to a third party.
Terminate the risk: where the risk cannot be brought below the Company’s risk appetite with proportionate effort/resource and no cost-effective transfer is available.

14.2. The Information Security Officer in collaboration with the Information Asset Owner reviews medium and low risks, and recommend suitable action.

15. Risk Appetite & Tolerance

15.1. The Company has agreed a series of risk appetite statements.

15.2. While not exhaustive, these give a good overview of the Company’s desire to pursue or tolerate risk in pursuit of its business objectives.

15.3. The risk appetite statements give the Information Security Officer a framework within which to conduct risk assessments and make recommendations for appropriate treatments.

Revised: 11/2024

Code of Ethics

This Policy is to establish guidelines and procedures for managing information risks within our Company

1. Purpose

1.1. Information that is collected, analysed, stored, communicated and reported upon might be subject to theft, misuse, loss and/or corruption.

1.4. It aims to protect the confidentiality, integrity, and availability of Company’s information assets and ensure compliance with relevant laws and regulations.

2. Objectives

2.1. The Company’s information risk management objectives are focused on:

information risks being identified, managed and treated according to a fixed risk tolerance;
the Information Asset Owner’s consent for physical, procedural and technical controls;
physical, procedural and technical controls are balanced with Employee/User experience and security;
physical, procedural and technical controls are cost-effective and proportionate.

3. Scope

4. Roles & Responsibilities

4.2. The Information Security Officer:

is responsible for managing the risk assessment process;
maintains an up-to-date risk register;
conducts risk assessments after which action for medium and low risks are recommended;
is responsible for assessing and reviewing high risks;
has visibility of the risk register; and
must also take an active role in identifying and reporting new risks.

5. Compliance & Review

6. Policy Statement

6.2. It is the Company’s policy to ensure that information is protected from a loss of:

Confidentiality: information will be lawfully accessible only to authorised individuals.
Integrity: the accuracy and completeness of information will be maintained.
Availability: information will be accessible to authorised Employees/Users and processed only as required by law or lawful purpose.

7. Information Classification

7.1. All information assets are classified based on their sensitivity and criticality.

7.2. This classification determines the level of protection required and the access controls to be implemented.

8. Access Control

8.1. Access to information assets is granted based on the principle of least privilege.

8.2. Only authorised individuals are given access, and access rights is regularly reviewed and revoked when no longer required.

9. Incident Response

9.1. An incident response plan is developed and maintained to address security incidents promptly and effectively.

9.2. This plan includes procedures for reporting, investigating, and mitigating incidents, as well as communication and notification requirements.

10. Training & Awareness

10.1. Regular training and awareness programs conducted to train Employees/Users on information risk management best practices, including the proper handling and protection of information assets.

11. Risk Assessment

11.1. Risk assessments must be completed with access to and an understanding of:

the Company’s business processes;
the impact to the Company of risks to business assets;
the technical systems in place supporting the business;
the legislation to which the Company is subject;
up-to-date threat and vulnerability assessments.

11.2.A risk assessment exercise should be completed:

for every new information-processing system;
following modification to systems or processes which could change the threats or vulnerabilities;
following the introduction of a new information asset;
following changes to the threat environment or detection of new vulnerabilities.

12. Threats & Vulnerabilities

12.1. The Company considers all potential threats and vulnerabilities applicable to a particular system, whether natural or human, accidental or malicious.

12.3. It is the responsibility of the Information Security Officer to maintain channels of communication with appropriate specialist organisations.

13. Risk Register

13.1. The calculations listed in the risk assessment process form the basis of a risk register.

13.2. All risks are assigned an owner and a review date.

13.3. The risk register is held in the Information Security document store, with access controlled by the Information Security Officer.

14. Risk Treatment

14.1. The risk register includes a risk treatment decision. The action must fall into at least one of the following categories:

Pending: where a potential risk has been identified but needs initial investigation.
Tolerate the risk: where the risk is already below the Company’s risk appetite and further treatment is not proportionate.
Treat the risk: where the risk is above the Company’s risk appetite but treatment is proportionate; or where the treatment is so simple and cost effective that it is proportionate to treat the risk even though it falls below the Company’s risk appetite.
Transfer the risk: where the risk cannot be brought below the Company’s risk appetite with proportionate treatment but a cost-effective option is available to transfer the risk to a third party.
Terminate the risk: where the risk cannot be brought below the Company’s risk appetite with proportionate effort/resource and no cost-effective transfer is available.

14.2. The Information Security Officer in collaboration with the Information Asset Owner reviews medium and low risks, and recommend suitable action.

15. Risk Appetite & Tolerance

15.1. The Company has agreed a series of risk appetite statements.

15.2. While not exhaustive, these give a good overview of the Company’s desire to pursue or tolerate risk in pursuit of its business objectives.

15.3. The risk appetite statements give the Information Security Officer a framework within which to conduct risk assessments and make recommendations for appropriate treatments.

Revised: 11/2024

Corporate & Social Responsibility Policy

1. Introduction

1.1. Our Corporate and Social Responsibility (CSR) Policy, outlines our Company’s commitment to ethical, sustainable, and socially responsible business practices in all aspects of our operations.

1.2. This Policy demonstrates our Company’s dedication to making a positive impact on society and the environment beyond its core business objectives.

2. Mission Statement

2.1. Main Portfolio LTD aims to contribute to the improvement of society, protect the environment, and support the welfare of our employees.

2.2. Our mission aims to:

Ethical Conduct: Operate with the highest ethical standards, integrity, and honesty in all our business activities.
Environmental Stewardship: Decrease our environmental footprint and promote sustainable practices throughout our functions.
Stakeholder Engagement: Engage actively with our stakeholders and listen to their concerns, needs, and feedback.
Employee well-being: Foster a safe, diverse, inclusive, and empowering workplace that values the well-being and development of our employees.
Community Investment: Contribute to the groups and communities in which we operate by supporting initiatives that address social issues and create positive change.

3. Key Principles

3.1. Ethics & Governance

We comply with all applicable laws, regulations and international standards.
We conduct our business with the highest ethical standards, promoting transparency and accountability.
We maintain a governance structure that ensures responsible decision-making at all levels of the organisation.

3.2. Environmental Sustainability

Sustainable Operations: We reduce our environmental impact by adopting eco-friendly practices, reducing waste, and conserving resources.
Resource Conservation: We responsibly manage natural resources, promote recycling and waste reduction, and minimize our ecological impact. We strive to use renewable energy and promote energy efficiency throughout our operations.
Product Responsibility: We encourage our suppliers to adhere to sustainable and responsible practices.

3.3. Stakeholder Engagement

We actively engage with customers, employees, suppliers, and the community to understand their concerns and needs.
We evaluate any feedback that we receive and work towards addressing any issues or suggestions.
We ensure transparent communication regarding our CSR efforts.

3.4. Employee well–being

We provide a safe and inclusive work environment free from discrimination and harassment.
We invest in employee training, development, and wellness programs.
We promote a healthy work-life balance and offer opportunities for career growth.

3.5. Community Investment

We contribute to the improvement of our local and global communities through philanthropic and volunteering efforts.
We support initiatives aligned with our CSR goals and values, with a focus on education, health, and social well-being.

3.6. Ethical Business Practices

Business Integrity: We conduct all business dealings with the highest level of ethical integrity, avoiding conflicts of interest and bribery.
Supplier and Partner Responsibility: We look for suppliers and partners who share our commitment to ethical and responsible practices.

3.7. Social Responsibility

Workplace Practices: We maintain a safe, inclusive, and respectful workplace where diversity is celebrated, and employees are treated fairly and with dignity.
Community Engagement: We actively support and engage in initiatives that enhance the quality of life in the communities where we operate.
Philanthropy: We contribute a portion of our resources to charitable and community-based organisations, focusing on causes that align with our values and goals.

3.8. Reporting & Accountability

Reporting: We communicate our CSR efforts and achievements transparently, both internally and externally, through regular reports and updates.
Accountability: We establish clear roles and responsibilities for CSR within our organisation and hold ourselves accountable for meeting our CSR goals and objectives.

4. Implementation & Review

4.1. Main Portfolio LTD is committed to the ongoing improvement of our CSR Policy.

4.2. We regularly assess and update this Policy to ensure it remains relevant and effective.

4.3. We also set measurable goals and report on our progress to our stakeholders.

This Policy is endorsed by Main Portfolio LTD’s leadership and is continuously communicated to all employees, suppliers, and partners. We expect the active involvement and support of everyone associated with our organization in achieving our CSR goals.

Revised:11/2024

Equal Employment Opportunity (EEO) Policy

1. Scope

1.1. This Policy covers rules to be followed with respect to:

Anti-discrimination of employee for hiring and promoting;
Consequences if not followed;
Reporting Mechanism; or
Investigation & Resolution Mechanism.

1.2. Main Portfolio LTD, recognise that everyone has a contribution to make to our society and a right to equal opportunity.

1.3. No job applicant or employee, member, volunteer or organisation/individual to which we provide services will be discriminated against by us on the grounds of:

age;
colour;
gender (including sex, marriage, gender re-assignment);
race (including ethnic origin, colour, nationality and national origin);
disability;
national origin;
sexual orientation;
religion or belief; or
veteran status.

2. Applicability

Applicable to HR and all the staff and business partners.

3. Objective

3.1. Main Portfolio LTD has endeavoured to capture the spirit of the Equal Opportunity Act 2010.

3.2. Equal Opportunity Act 2010 replaced all previous anti-discrimination laws, including the Anti-Discrimination Act (1977), with a single Act, making the law easier to understand and strengthening protection in some situations.

3.3. Main Portfolio LTD is committed to promoting equal employment opportunities and a workplace that is free of all forms of discrimination. Equal opportunity means that all staff experience fairness, impartiality and equal access to all career initiatives in the Main Portfolio LTD.

3.4. Main Portfolio LTD commitment to equal opportunity promotes an inclusive work environment that values and accepts the diverse cultural and social backgrounds of its staff.

3.5. Main Portfolio LTD will take affirmative action to ensure that this Policy is implemented, with particular regard to: advertising, application procedures, compensation, demotion, employment, fringe benefits, job assignment, job classification, layoff, leave, promotion, recruitment, rehire, social activities, training, termination, transfer, upgrade, and working conditions.

4. Aim & Commitment

4.1. This Policy aims to make workplace free from discrimination, sexual harassment and victimisation.

4.2. We Aim

To promote equal opportunities, eliminate discrimination and harassment through the following:

Opposing all forms of unlawful and unfair discrimination.
All employees (whether part-time, full-time or temporary), associates, independent contractors and beneficiaries shall be treated fairly and with respect.
All employment opportunity announcements/vacancies will be advertised internally and externally simultaneously and will include a statement on equal opportunities to make it understood that the foregoing is Company Policy and all employment decisions are based on individual merit only. Selection for employment, promotion, training or any other benefit will be based on aptitude and ability. Main Portfolio LTD will continue by the employment entities with which it deals, that the foregoing is a mandatory Company Policy. All selection/rejection decisions will be recorded.
All employees (whether part-time, full-time or temporary), associates, independent contractors and beneficiaries shall be assisted and encouraged to develop their full potential and the talents and resources of individuals will be fully utilised to maximise the efficiency of the organisation.
It is the Company’s Policy to ensure and maintain a working environment free of coercion, harassment, and intimidation at all job sites, and in all facilities at which employees are assigned to work. All employees (whether part-time, full-time or temporary), associates, independent contractors and beneficiaries have a legal and moral obligation not to discriminate and to immediately report any violation of the policy or any incidents of discrimination against any individual or group of individuals to their supervision.
It is our Company’s Policy that all company activities, facilities, and job sites are non-segregated. Separate or single-user toilet and changing facilities are provided to assure privacy.

4.3. We Commit:

To create an environment in which individual differences and the contributions of all our staff, volunteers, members and beneficiaries are recognised and valued.
Every employee, volunteer, member and beneficiary are entitled to be part of an environment that promotes dignity and respect for all. No form of intimidation, bullying or harassment will be tolerated.
Training, development and progression opportunities are available to all staff members.
Equality is good management practice and makes sound sense. Breaches of our equality Policy will be regarded as misconduct and could lead to disciplinary proceedings or employee formal warning or termination of employment or cooperation.
This Policy is fully supported by the management committee and has been agreed upon by all its members and the employee representatives.
The Policy will be monitored and reviewed annually.

4.4. The successful implementation of this Policy depends on the awareness and commitment of all staff members and associates. Hence, all new staff members and associates will be made aware of its existence and on joining the organisation, and reminded they must conform with it on a regular basis.

5. Policy Objective

5.1. The objectives of this Equal Employment Opportunity (EEO) and Anti-Discrimination Policy are to ensure that all:

Main Portfolio LTD’s employees or potential employees do not suffer unfair discrimination in the workplace.
Individuals and groups within the Main Portfolio LTD work in an environment where all decisions are free of discrimination, where they have equal opportunity based on relevant abilities, skills and merit.
Employees are encouraged to take positive action towards promoting equal opportunity throughout the organization.
Personnel actions such as compensation, benefits, transfers, layoffs, company-sponsored training programs and social and recreational programs will be administered on a non-discriminatory basis.
Application of labour laws to be uniformly applied in the organization.

6. EEO & Provisions of Services

6.1. It refers to the principle which ensures that all employees and potential employees of Main Portfolio LTD are treated equitably and fairly regardless of their race, sex or disability.

6.2. Everyone has an equal chance when applying for jobs, transfers, promotions, training opportunities and in their working conditions.

6.3. The following activities shall be conducted in a uniform manner:

Recruitment procedure and selection criteria for appointment or engagement of a person as an employee;
Promotion and transfer of an employee;
Training and staff development for an employee; and
Terms of employment or any other employee-related activity

7. What is Workspace Discrimination

7.1. Discrimination occurs when someone is treated unfavourably because of a certain attribute. Discrimination may involve some or all of the following:

Conduct that can be considered harassing, coercive or disruptive, including sexual harassment.
Making offensive ‘jokes’ about another worker’s clan, ethnic background, colour, sex, appearance or disability.
Expressing negative stereotypes about particular groups, e.g., “married women shouldn’t be working”.
Judging someone on their political or religious beliefs rather than their work performance.
Using selection processes based on irrelevant attributes such as ethnic or clan group, age, sex or disability rather than on knowledge, skills and merit.

8. Parameters of Discrimination – Strictly Prohibited

8.1. Main Portfolio LTD and its employees shall strive to create a workplace that is free from discrimination in their employment practices against any potential or existing employees, and shall not discriminate on a person’s:

Age or other circumstances
Colour
Cultural or social beliefs such as religious
Educational background
Race, ethnicity or nationality
Spiritual, traditional or customary beliefs
Political opinion
Physical features or physical disabilities
Gender identity and expression
Marital status
Pregnancy or judging the impacts of potential pregnancy on decisions
Breastfeeding
Sexual orientation
Health or physical disability or impairment
Medical record
HIV status
Family responsibilities
Trade union membership
Reserve disciplinary forces, e.g., police

9. Modern Slavery Statement

9.1. Main Portfolio LTD has a zero-tolerance approach to any form of modern slavery and human trafficking.

9.2. These behaviours and acts are strictly prohibited and we are committed to acting ethically, with integrity and transparency in all business dealings and to implementing effective systems and controls in place to safeguard against any form of modern slavery taking place within our business or our supply chain.

9.3. We expect all those in our supply chain to comply with our values fully. We use the following key performance indicators to measure how effective we have been in ensuring that slavery and human trafficking are not taking place in any part of our business or supply chains.

10. Complaint Process & Procedures

10.1. A person wishing to make a complaint of discrimination can consult and file a complaint with the EEO & Anti-Discrimination (AD) Committee. The complaint should be made in writing and addressed to chairperson of the committee within five (5) working days of any such incident of discrimination.

10.2. The constitution of the Committee shall be:

Chair of the “EEO & Anti-Discrimination” Committee
Internal Officers – 2 Members from Middle-Level Management [One Female & One Male]
HR Department Head

11. Process to Be Followed

Once a complaint has been filed with the EEO & AD Committee:

11.1. Investigation

Once a complaint has been filed, an investigation will be undertaken immediately. In instances where there is an alleged respondent, the respondent will be notified immediately.
The complainant and the respondent will both be interviewed along with any individuals who may be able to provide relevant information.
Where the alleged discrimination is an organizational practice or procedure, that practice or procedure will be investigated immediately.
Where the investigation finds systemic discrimination within the organization, that practice or procedure will be changed promptly.

11.2. Mediation

Main Portfolio LTD supports resolving matters through mediation provided that it is consistent with organizational duties, obligations and needs. Mediation can only be undertaken voluntarily.
If both parties agree to participate, matters may be resolved through mediation in the following circumstances.
Once the matter has been investigated and Main Portfolio LTD has determined the facts of the case, Main Portfolio LTD may use mediation to develop appropriate solutions to the complaint; and, in rare instances, where the incident is an isolated event and the parties do not dispute the facts, Main Portfolio LTD will act diligently to ensure that matters are dealt with in a manner that ensures the safety and protection of everyone within the organization.

11.3. Timelines

Main Portfolio LTD will investigate all complaints immediately and will work towards the prompt resolution and prevention of discriminatory acts and practices.
The first round of investigation and conclusion shall be arrived at within ten (10) working days from the date of filing of the complaint.

11.4. Fairness

All complaints will be investigated in the same manner with the aim of promoting, fairness and equality.

11.5 Confidentiality & the Right to Privacy

Main Portfolio LTD will preserve the confidentiality of all individuals involved in a discrimination complaint. The preservation of confidentiality may be affected by the employer’s duty to prevent discrimination in/at Main Portfolio LTD and by the alleged respondent’s right to know the nature of the complaint being made against them and who has made it so that they can respond.
If the investigation fails to find evidence to support the complaint, no documentation concerning the complaint will be placed on the file of the respondent. Main Portfolio LTD will retain all documentation for twelve (12) months for informational purposes in the event that there is an internal appeal or a complaint filed with an outside agency.

11.6. Outcomes & Remedies

Main Portfolio LTD will act swiftly to ensure that the discriminatory practice is stopped as soon as possible and may remedy the situation in a number of ways.
Where the investigation determines that discrimination has occurred or the matter has been successfully mediated, outcomes may include moving the respondent to another department, changing the respondent’s job duties, or a letter of apology.
Actions taken to remedy a discriminatory situation should not have a negative effect on the complainant.
The main concerns of the employer will be to ensure that the discrimination ends and to restore workplace harmony.

11.7. Appeal Process

Within ten (10) days from the result of the first round of investigation, either the complainant or the respondent may make a written request that an investigation be reviewed stating which aspect of the investigation is inadequate. The request must be submitted to CEO of Main Portfolio LTD, who will determine if the investigation is to be re-opened in order to address the concerns raised.
In case the appeal is taken up, then the investigation shall be completed within fifteen (15) working days by the same committee with the inclusion of an independent member.
The result of the appeal shall be binding on the complainant, respondent and all related parties concerned for all purposes.

12. Special Circumstance & Exception

12.1. No exception to this Policy is allowed. Any Deviation from this Policy has to be approved by HR.

12.2. Any changes to this Policy need to be approved by Legal and Compliance.

13. Non-compliance & Consequence

13.1. Any instances of discrimination or favouritism with proper evidence that comes to or is brought to the notice of the management will be dealt with strictly in accordance with the terms of this Policy and any other appropriate policies of the Company.

Revised: 11/2024

Workplace Anti-Bullying & Anti-Harassment Policy

1. Policy Statement

1.1. Main Portfolio LTD (the “Company”) seeks to provide a work environment that is safe and enjoyable for all. Bullying and harassment is a behaviour that makes someone feel intimidated or offended. Harassment is unlawful under the Equality Act 2010.

1.2. Workplace bullying and harassing behaviours have a detrimental eﬀect on the Company and its people. Due to these behaviours is created an unsafe working environment, result in a loss of trained and talented staff, cause the breakdown of teams and individual relationships, increase absenteeism and reduce eﬃciency and productivity.

1.3. Examples of bullying or harassing behaviour include, but are not limited to:

spreading malicious rumours
unfair treatment
picking on or regularly undermining someone
denying someone’s training or promotion opportunities

1.4. The unwanted behaviour is related, indicative and not exhaustive, to one of the following:

age
sex
disability
gender reassignment
marriage and civil partnership
pregnancy and maternity
race
religion or belief
sexual orientation

1.5. Bullying and harassment can happen:

face-to-face
by letter
by email
by phone

1.6. This Policy applies to behaviours that occur:

In connection with work, even if it occurs outside normal working hours;
During work activities, for example, when dealing with clients;
At work related events and functions, for example, at Christmas parties; and
On social media platforms where staff members interact.

1.7. The Company recognises that workplace bullying may involve comments and behaviours that oﬀend some people and not others.

1.8. The Company accepts that individuals may react diﬀerently to certain comments and behaviour.

1.9. That is why a minimum standard of behaviour is required of all staff members. This standard aims to be respectful of all staff. This Policy applies to all staff members including employees, contractors, associates, trainees and volunteers.

2. Application

2.1. This Policy applies to all current employees of Main Portfolio LTD, including full and part-time, casual, contract, permanent and temporary employees. This policy also applies to job applicants.

2.2. This Policy applies to all behaviour that is in some way connected to work, including during off-site meetings, training and on business trips.

3. Responsibilities & Expectations

3.1. Employees should see if they can sort out the problem informally first. If they cannot, they should talk to:

Their Manager/Supervisor;
The Human Resources (HR) Department;
The Trade Union representative (if applicable).

3.2. Complaints of bullying, harassment and workplace violence will be taken seriously and will be handled immediately.

3.3. If any of the employees make a complaint of workplace bullying, harassment or violence it will be taken seriously and will be dealt with sympathetically and in a conﬁdential manner (except where the Company deems it is necessary to disclose information in order to properly deal with the complaint). Staff members will not be victimised or treated unfairly for making a complaint.

3.4. Managers’ and supervisors’ roles: Managers and supervisors should also ensure that all staff members understand this Policy and consequences of non-compliance. When managers and supervisors observe harassment, bullying or workplace violence occurring, they should take steps to prevent this conduct from continuing and warn the person or people involved of the consequences if the behaviour continues (including disciplinary measures up to and including termination of employment).

3.5. Staff’s Role: The Company expects staff members:

Not to engage in harassment, bullying or workplace violence;
Not to aid, abet or encourage others to engage in harassment, bullying or workplace violence; To behave in a responsible and professional manner;
Treat others in the workplace with courtesy and respect;
Listen and respond appropriately to the views and concerns of others; and
To be fair and honest in their dealings with others.

4. Other Measures

4.1. The Company also recognises the need for open communication in the workplace.

4.2. The Company may implement what training it considers necessary in relation to behavioural standards and where appropriate will hold meetings to address standards, expectations and any issues.

4.3. The frequency, dates and form of this training and meetings will be determined by management of the Company.

5. Privacy &Confidentiality

5.1. All parties to a harassment complaint are expected to respect the privacy and confidentiality of all other parties involved and to limit the discussion of a harassment complaint to those that need to know.

5.2. Main Portfolio LTD and all individuals involved in the harassment complaint process, will comply with all requirements of the any and all applicable privacy legislation to protect personal information.

6. More Information & Enquiries

6.1. If you need any more information about workplace bullying, harassment, or violence please contact your Manager/Supervisor and/or the HR Department.

6.2. Enquiries about this Policy and related procedures can be made to your Manager/Supervisor and/or the HR Department.

Revised: 10/2024

Statement of Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF) Policies and Principles

1. Introduction

1.1. Money Laundering and Terrorist Financing have been identified as major threats to Main Portfolio LTD (hereinafter our/the “Company”) and, indeed, the international financial services community. The United Kingdom, along with many other countries, has passed legislation to prevent money laundering and combat terrorism.

2. Legal & Regulatory Framework

2.1. The principal requirements, obligations and penalties on which our Company’s financial crime systems and controls are based derive from:

The proceeds of Crime Act 2002 (POCA), as amended by the:
Serious Organized Crime and Police Act 2005 (SOCPA); and the
Proceeds of Crime Act (amendment) Regulations 2007;
The Terrorism Act 2000, as amended by the:
The Anti-Terrorism, Crime & Security Act 2001; and the
Terrorism Act (amendment) Regulations 2007;
The Terrorism Act 2006;
The Bribery Act 2010;
The Money Laundering Regulations 2007, transposing the requirements of the E.U.’s third money laundering directive;
The FCA handbook of rules and guidance, and in particular, the senior management arrangements, systems and controls (SFFISC) sourcebook, which relates to the management and control of money laundering risk; and
The Joint Money Laundering Steering Group (JMLSG) guidance for the UK financial sector prevents money laundering / combating terrorist financing.

3. Our Company’s Policies & Principles

3.1. Main Portfolio LTD is responsible for the following policies covering:

Anti-Money Laundering ⁄ Counter-Terrorist Financing ⁄ Counter-Proliferation Financing;
Training;
Anti-Bribery & Anti-Corruption; and
Introducers.

3.2. These policies and principles are designed to ensure that all group companies comply with the legal and regulatory requirements in the UK and with their local obligations.

4. Anti-Money Laundering (AML) Policy

4.1. Our Company’s AML Policy is designed to ensure compliance with the requirements and obligations set out in UK legislation, regulations, rules and industry guidance for the financial services sector, including the need to have adequate systems and controls in place to mitigate risks in firms that are used to facilitate financial crime. The AML Policy sets out the minimum standards, which all our companies must comply with and includes:

Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KFFIC) procedures, including enhanced due diligence for those customers presenting higher risk, such as politically exposed persons (peps) and correspondent banking relationships;
Establishing and maintaining risk-based systems and procedures to monitor ongoing customer activity;
Developing procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
Maintaining appropriate records for the minimum prescribed periods;
Training and awareness for all relevant employees; and
Providing appropriate management information and reporting to senior management of the group’s compliance with the requirements.

5. Training

5.1. All employees receive training on the Anti-Money Laundering and Counter-Terrorist Financing policies and principles at least once a year, with more detailed and advanced training for those whose roles involve major financial risks.

5.2. Failure to comply with these policies and principles may give rise to disciplinary action, up to and including dismissal.

6. Anti-Bribery & Anti-Corruption Policy

6.1. We have a zero-tolerance Policy toward bribery and corruption. Our Company recognises that bribery and corruption adversely affect communities wherever they occur. They can threaten laws, democratic processes and fundamental human freedoms while distorting free trade and competition.

6.2. Corruption is often associated with organised crime, money laundering and, on occasion, the financing of terrorism. In addition, the level and efficacy of investment and financing can be reduced, particularly within economically disadvantaged societies.

6.3. We are committed to applying high standards of honesty and integrity consistently across our global operations and in all our business dealings. Our Company is subject to the provisions of the UK Bribery Act 2010 and international foreign corrupt practices act, which have an extra-territorial effect globally, as well as applicable local anti-bribery laws in relevant jurisdictions.

7. Introducers

7.1. In addition to the anti-bribery and anti-corruption Policy, our Company has an introducer clause described in the Introducer Agreement. The clause covers the activities of all third parties that generate or retain business or secure a business benefit for us. These third parties are termed “introducers” by Main Portfolio LTD. Potential examples would include senior advisors, lead generators, and existing clients of our Company.

7.2. Our Introducer Policy protects our Company against bribery and corruption risks, reputational risk, and broader operational and conduct risks associated with introducers. Our employees must apply the specific controls and procedures set out in the Policy.

8. Governance & Conformance

8.1. Regular reviews of the effectiveness of these group policies are carried out in addition to audits periodically undertaken by our Company’s internal audit function.

8.2. This provides senior executive management oversight committees and the board audit committee with the necessary assurance regarding the operating effectiveness of the group’s controls relating to these policies.