ANTI-MONEY LAUNDERING AND COMBATING THE FINANCING OF TERRORISM (AML/CFT) POLICY

INTRODUCTION

• The combating of money laundering and the financing of terrorism has, in recent years, become a challenge of global proportions. Money launderers, terrorists and criminal groups have become more sophisticated in their methods and techniques.
• For the purpose of this policy (“the Policy”):

MONEY LAUNDERING IS:

• The process by which criminals attempt to conceal the true origin and ownership of the proceeds of criminal activities. If successful, the money can lose its criminal identity and

THE FINANCING OF TERRORISM IS:

• An offense within the meaning of the UN International Convention for the Suppression of the Financing of Terrorism (1999), where a person by any means, directly or indirectly, unlawfully and willingly, provides or collects funds with the intention that they should be used or in the knowledge that they are to be used, in full or in part, in order to carry out
• An act which constitutes an offence within the scope of and as defined in one of the treaties listed in the annex of the above-mentioned treaty, or
• Any other act intended to cause death or serious bodily injury to a civilian, or to any other person not taking any active part in the hostilities in a situation of armed conflict, when the purpose of such act, by its nature or context, is to intimidate a population or to compel a government or an international organisation to do or to abstain from doing an act.
• For an act to constitute an offense set forth in paragraph 1, it shall not be necessary that the funds were actually used to carry out an offense referred to in paragraph 1, subparagraph (a) or (b).
• The UAE, cognizant of the need for regulatory legislation, has enacted numerous laws at federal level to prevent and criminalize money laundering and the financing of terrorism.

KNOW YOUR CUSTOMER

To determine whether your customers fit into the high-risk category, it is advisable to check the following:

• Identifying the customer and obtaining identification information from him. This information includes full name, unique identification number, existing residential address, contact telephone number, date of birth and nationality. Different particulars are required from non-personal customers such as companies.
• Know your customer form must be update regularly.
• Verifying the identity of customers using reliable, independent sources, and keeping a copy of all reference documents used to verify their identity.
• Identifying and verifying the identity of payees before making certain types of payment such as surrendering a life insurance policy or refunding a premium.
• Paying attention to all unusual transactions.

Periodically reviewing customer identification information to ensure the information is kept up-to-date.

PREVENTIVE MEASURES

The Company has taken following Preventive measures for mitigating the risk

• The company has established and maintain effective internal policies, procedures, and controls to prevent opportunities for money laundering. The money laundering compliance program should be defined by the higher management or the board of directors. Companies must consider local regulations prior to adopting a compliance program.
• The Company always obtains details of customers in order to verify their identities, including full name and address, passport or identity card (for individuals) and trade license (for companies). Such information is periodically and regularly updated. The more a company knows about its customers, the better can money laundering abuses be prevented.
• The company has adopted policies and procedures for the identification and reporting of suspicious activity. A company always review UAE regulations for what it considered to be a suspicious transaction as well as the allowable time delays to report such activity.
• The company established an ongoing employee-training program for all employees. Training present real-life money laundering examples, preferably cases that have occurred in the company, including how the pattern of activity was first detected and its ultimate impact on the company.

REPORTING OF SUSPICIOUS ACTIVITIES

The Company has placed a clear obligation on all Links staff and Members to report any suspicious activities or information which may point to transactions, instructions, or arrangements with which Links is involved, being related to illegal activities. As money laundering and the financing of terrorism methods and techniques are always evolving, the Company will issue regular circulars as what are to be considered as red flags for suspicious activities in both money laundering and financing of terrorism. These red flags will be the base on which the SARs should be filed by the different parties subject to this Policy. The red flags will also cover the attempted transactions.

As such, it is the legal duty of management, staff and Members to report any suspicious activity or information to the Company. In doing so, it is important that:

• The reason for the suspicion is fully explained; and
• Any additional information as may be requested by the Company is duly provided

The Company will investigate the report and will decide on the information available together with any additional enquiries whether or not to file a Suspicious Activity Report with the Anti-Money Laundering and Suspicious Cases Unit of the UAE Central Bank.

TRAINING AND AWARENESS

This Policy will be communicated to all employees during the initial staff induction process and as appropriate, thereafter in accordance with the commitment to ensure that all employees receive ongoing training.

AMENDEMENT OF THIS POLICY

Links is committed to continuously reviewing and updating our policy and procedures based on the learning. Links will monitor the effectiveness and review the implementation of this Policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Therefore, this document is subject for modification. Any amendment or waiver on any provision of this Policy must be approved in writing by the top management. This Policy will be reviewed and audited from time to time which requires cooperation from all concerned.

BUSINESS ETHICS AND CODE OF CONDUCT POLICY

INTRODUCTION

General Policy and Procedures- The reputation of Links Insurance Brokers LLC, (“Links or the “Company”) is based on the conduct, integrity and abilities of our colleagues. The Company expects all of its colleagues to share its commitment to high ethical and legal standards and to avoid any activities that could involve the Company or its colleagues in any real or perceived unethical, improper, or unlawful act. As used in this policy, the terms “colleague” and “employee” shall refer to all colleagues (including all employees of the Company), as well as the officers and, as applicable, directors of the Company, unless otherwise indicated.

Careful review of this policy will provide colleagues with a better understanding of the Company’s expectations and of colleagues’ own obligations. Compliance with this policy is mandatory and it is the duty of all colleagues to familiarize themselves with the policy as well as the legal standards and policies specifically applicable to their assigned duties and to conduct themselves accordingly. Compliance with this policy will be a factor in each employee’s performance review. Violations of this policy are subject to discipline, up to and including termination of employment.

Additional Requirements- The policy is not intended to be an exclusive set of guidelines or requirements governing the conduct of colleagues. The Company has adopted and may amend or adopt other corporate policies, procedures, personnel manuals or employee handbooks that also proscribe or specify conduct. Moreover, no single policy or set of policies can ever be totally comprehensive or serve as a substitute for the good judgment, common sense and proper, ethical and legal conduct we expect of all colleagues.

COMPLIANCE WITH LAWS AND ETHICAL BUSINESS CONDUCT

Recognition of the public interest is a permanent commitment of the Company in the conduct of its business. The activities of the Company must always be in compliance with all applicable laws, statutes, and regulations. Colleagues occupy positions of trust and confidence. In discharging their responsibilities, each employee has a duty to serve the Company, in good faith, in a manner that he or she reasonably believes to be in the best interests of the Company and its stockholders and with such care as an ordinary prudent person in a like position would use under similar circumstances. Colleagues also have duties of condor, care and loyalty to the Company. These duties include, but are not limited to, the duty to make a reasonable inquiry where the circumstances require such inquiry; the duty to disclose all material information relevant to corporate decisions from which that person may derive, directly or indirectly, a personal or other benefit; the duty to deal openly with and make full disclosure to the Company; the duty to avoid and disclose any activities which could create, or appear to create, a conflict with the interests of the Company, the duty not to exploit one’s positions with the Company by improperly converting money or other property which lawfully belong to the Company; and the duty to act with integrity, fidelity, and high standards of conduct.

CONFLICTS OF INTEREST

Except as provided elsewhere in this policy, or to the extent a right to do so is protected by law, colleagues must avoid employment or business activities, including personal investments, that interfere with their duties to the Company, divide their loyalty, or create or appear to create a conflict of interest, unless such employment or activities are fully disclosed to the Company and approved by written consent. It is not possible to provide a precise, comprehensive definition of a conflict of interest. However, one factor that is common to all conflict-of-interest situations is the possibility that a person’s actions or decisions may be affected or have the appearance of being affected because of an actual or potential divergence between the interests of the Company and some other interest, including that person’s own personal interests. Conflicts of interest also arise when a colleague, officer or director, or a member of his or her family, receives improper personal benefits as a result of his or her position in the Company. Loans to, or guarantees of obligations of, such persons are of special concern. A particular activity or situation may be found to involve a conflict of interest even though it does not result in any financial loss to the Company and irrespective of the motivations of the person involved. Other factors to be considered in determining whether a conflict of interest exists include:

• whether it may interfere with the employee’s job performance, responsibilities or morale;
• whether the employee has access to confidential information;
• whether it may interfere with the job performance, responsibilities or morale of others within the organization;
• any potential adverse or beneficial impact on our business;
• he extent to which it would appear improper to an outside observer.

FAIR DEALING

The Company depends on its reputation for quality, service and integrity. The way we deal with our customers, competitors, and suppliers moulds our reputation, builds long-term trust and ultimately determines our success. Colleagues should endeavour to deal fairly with the Company’s customers, suppliers, competitors and each other. Colleagues must never take unfair advantage of others through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair dealing practice. r. However, colleagues should remember that their first duty in this regard is to the Company, and accordingly, any disclosure of any confidential information, including pricing or negotiating information, without the prior approval of the top management shall be subject to discipline, up to and including termination of employment, and such other legal remedies as may be available to the Company.

RECEIPT OF GIFTS, GIFT CARDS, ENTERTAINMENT, FAVOURS OR OTHER GRATUITIES

Link’s policy is that the opportunity to do business with Links cannot be bought by any third party by giving gifts to Links colleagues who might be in a position to influence approval of a customer’s or vendor’s business. To enforce this policy, no colleague is allowed to accept any gifts, gift cards, entertainment, favours or other gratuities from any person or organization if such a gift would influence decision-making at Links. To avoid even the appearance of impropriety, the following restrictions apply to colleagues and to their Immediate Families with respect to favours from outside sources that do business, or are seeking to do business, with Links:

• You may not give or offer a gift to, or accept a gift from, anyone with whom the Company conducts business where the gift would exceed customary courtesies associated with accepted ethical and general commercial practice. The purpose of this requirement is to ensure that the offer or acceptance of a gift does not create an obligation, or be construed by others to allege favouritism, discrimination or other unacceptable practice.
• Receiving or giving gifts of cash is strictly prohibited.
• If you are requested to offer gifts that exceed the customary courtesies or that could give the appearance of impropriety, you must immediately consult your supervisor and/or the head of your business unit. A gift should not be accepted when to do so is either prohibited under local law or could be viewed as done for the purpose of influencing a business decision or appears to create a conflict of interest for those involved.

USE OF THE COMPANY FUNDS OR OTHER RESOURCES

A colleague who has access to Company funds must follow the prescribed procedures for recording, handling and protecting money as detailed in the Company’s manuals or other written policy documentation. Where a colleague’s position requires spending of Company funds or incurring any personal expenses to be later reimbursed by the Company, it is the individual’s responsibility to use good judgment on the Company’s behalf and to ensure that good value is received for every expenditure, and to follow all Company policies and procedures relating to authorization and approval for such expenditures. Company funds should only be used for Company purposes and must not be used for personal benefit.

CORPORATE RECORDS

It is Company policy to make full, fair, accurate, timely and understandable disclosure in compliance with all applicable laws and regulations in all reports and documents and in all other public communications made by the Company. Accurate and complete record keeping is essential to the corporate well-being of the Company and to enable it to comply with legal and regulatory requirements, to manage the affairs of the Company and to provide the best possible service to its customers. The Company adheres to a strict policy of maintaining complete and accurate books and records including, but not limited to, memoranda, expense reports, accounts, contracts, financial reports and other business or corporate records. The Company’s books and records must reflect, in an accurate and timely manner, all business transactions. Undisclosed or unrecorded funds, other assets, or liabilities are not permitted. All persons are expected and required to prepare, preserve and produce all books and records in accordance with this policy.In order to protect the privacy of Company officers and colleagues and comply with federal and state law, colleagues must ensure that all records containing medical or personal data about colleagues are kept confidential and only disclosed as authorized.

DISCIPLINARY ACTION AND VIOLATIONS OF THE POLICY

Violations of this policy will be grounds for discharge or other disciplinary action, based on the circumstances of the particular violation. Disciplinary action will be taken, not only against individuals who authorize or participate directly in a violation of the policy, but also against any of the violator’s management, to the extent that the circumstances of the violation reflect inadequate supervision by the superior. Compliance with this policy will be a key factor in the evaluation of the individual’s overall performance.

Anti-Bribery and Corruption Policy

INTRODUCTION

The Links Insurance Brokers LLC is committed to ethical business practices and in particular, to compliance at all times with applicable anti-bribery and anti-corruption laws in all countries where the company carry on business (collectively, the Anti-Corruption Laws). The principles in this anti-bribery and corruption policy document (the Policy) apply to the full range of the company’s business activities around the world. In addition to legal requirements, the company believes that long term, successful business relationships are built on honesty, fairness, and the strength of the company’s products and services, and not on unethical business practices. This Policy provides clear rules for company personnel and third parties engaged in company business, to ensure compliance with the Anti-Corruption Laws and the company’s ethical standards and expectations.

PROHIBITION AGAINST BRIBES AND IMPROPER PAYMENTS

Company Personnel and Business Partners are prohibited from:

• making or receiving bribes in connection with company business; and
• offering or receiving any financial or other advantage to or from another party with the intention to influence or reward the improper performance of an activity.

Bribes can take on many shapes and forms but typically they involve corrupt intent. There will usually be a quid pro quo – both parties will benefit.

• A bribe could be direct or indirect promise, offering or authorization of anything of value or the offer or receipt of any kickback fee, reward or other advantage.
• Bribery is the offer, promise, giving, demanding or acceptance of an advantage as an inducement for an action which is illegal or unethical.
• Corruption is the misuse of public office or power for private gain, or misuse of private power in relation to business outside the realm of government.
• Acts of bribery or corruption are designed to influence the individual in the performance of their duty and induce them to act dishonestly.

The use of intermediaries (including agents) for the payment of bribes or other improper payments is prohibited.

TRAINING AND AWARENESS

This Policy will be communicated to all employees during the initial staff induction process and as appropriate, thereafter in accordance with the commitment to ensure that all employees receive ongoing training.

COMPLIANCE

It is the responsibility of all company Personnel to understand and comply with this Policy.

IMPLEMENTATION

Local management is responsible for implementation of this Policy and ensuring their employees are aware of the Policy. Any company Personnel who have any question in respect of the Policy should address this to his local management.

KEY RISK AREAS FOR BRIBERY AND CORRUPTION

• Gifts and Hospitality

Gifts include the receipt or offer of gifts, meals or tokens of appreciation and gratitude, or invitations to events, functions, or other social gatherings, in connection with matters related to our business. When necessary or appropriate in the ordinary course of business, it is generally acceptable to give and receive occasional gifts or hospitality, provided the following requirements are met:

• It is made as an expression of goodwill and is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange of favours or benefits;
• It is compliant with federal laws and regulations, including recipient’s own rules;
• It complies with the generally accepted standards of hospitality taking into account the norms of the industry or professional sector to which it is offered, or is otherwise appropriate or customary, given the circumstances (i.e. if it is customary to provide small gifts during Eid Holidays);
• Conflict of Interest
  Conflict of interest may occur when delegating personnel, the responsibility or authority for making decision in relation to which there is a risk of bribery. The decision process and the level of authority of the decision-maker/s shall be free of actual or potential conflict of interest. Delegation of decision making will not exempt top management of their duties and responsibilities nor will it transfer to the delegated personnel potential legal responsibilities.
• Business entertainment
  The form and cost of acceptable business entertainment will depend on a number of factors, including the nature of the relationship with the host or guest, the cost and standard of living in the region and the acceptable forms of business entertainment or hospitality in the region. Should you have any doubt as to what is acceptable in any particular situation you should consult your supervisor and/or the head of your business unit. Business entertainment or hospitality expenses must be properly recorded in the Group member’s books and records.

BREACHES AND REPORTING

Breach of this Policy may result in disciplinary action for Company employees up to and including termination and/ or referral to national law enforcement authorities. Breaches of the Anti-Corruption Laws could also subject the individual who committed the violation to civil or criminal penalties, including substantial fines and potentially lengthy imprisonment. For Business Partners, breach of this policy will lead to termination of the relationship with the Group.

AMENDMENT OF THIS POLICY

Links is committed to continuously reviewing and updating our policy and procedures based on the learning. Links will monitor the effectiveness and review the implementation of this Policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Therefore, this document is subject for modification. Any amendment or waiver on any provision of this Policy must be approved in writing by the top management. This Policy will be reviewed and audited from time to time which requires cooperation from all concerned.

COMPETITION LAW AND ANTI-COMPETITIVE PRACTICES POLICY

INTRODUCTION

Links Insurance Brokers LLC (the ‘Company’) is committed to compliance in full with all laws and regulations governing its businesses including laws relating to competition. The Company strives to adhere in all of its business practices to the principle of fair and effective commercial competition between businesses. This means making sure that all employees understand what the law requires and act accordingly. It does not engage in conduct which is anti-competitive, nor will it enter into agreements with other companies or organisations (whether private or publicly owned) which could, or do, or intend to restrict, prevent or distort competition in any market in which we operate.

COMPETITION LAW

The provisions of this Law shall apply to the economic activities carried out by the Organizations in the UAE and to the exploitation of intellectual property rights inside and abroad the UAE. This Law shall also apply to the economic activities which are practiced abroad the UAE and affect competition in the UAE.

The following activities are anti-competitive and therefore unlawful

• Agreements which have as their subject or objective the abuse, restriction or prevention of competition shall be prohibited, in particular the agreements that aim to
• fixing, directly or indirectly, purchase or sale prices of goods or services by causing increase, reduction, or fixing of prices, thereby adversely affecting Competition
• determining the terms and conditions of sale, purchase, or performance of services, or any similar transaction.
• collusion in bids or proposals in tenders, practices, and other supply offers
• freezing or limiting production, development, distribution or marketing, and other investment aspects.
• conspiracy not to purchase from certain organization or organizations, limiting sale or supply to certain organization or organizations, and preventing or obstructing its/their ability to carry out its/their business.
• restricting the freedom of supply of goods or services to the Relevant Market, or removing goods or services from the Relevant Market, including hiding or unlawfully storing goods or services, abstaining from dealing in goods and services, or creating a sudden oversupply that leads to circulating the goods and services at fake prices

CONSEQUENCES OF NOT COMPLYING

The penalties for not obeying these laws can be very severe with high fines on the Company and life/career changing effects on the individual. In addition, there are of course the damaging effects of such bad publicity on the business as well. This policy is intended to provide information, requirements and guidance to protect the Company and its employees. Any employee in any doubt about any aspect of the law, this policy, their role and/or actions as they relate to competition must refer the matter to their line manager immediately.

PREVENTING ANTI-COMPETITIVE PRACTICES

The Company has in place a number of measures to prevent, detect and prohibit anti-competitive practices, including the engagement of external experts. The Company will regularly, where relevant, identify employees or officers of the Company who are in positions where competition law is pertinent. Employees and associated persons are requested to assist the Company and to remain vigilant in preventing, detecting and reporting any incidences of anti-competitive practices. The Company will fully investigate any instances of alleged or suspected bribery. Employees suspected of bribery may be suspended from their duties while the investigation is being carried out. The Company will invoke its disciplinary procedures where any employee is suspected of bribery, and proven allegations may result in a finding of gross misconduct and immediate dismissal. The Company may terminate the contracts of any associated persons, including consultants or other workers who act for, or on behalf of, the Company who are found to have breached this policy.

REVIEW

The Company communicates periodically to employees and associated persons on the matter of anti-competitive practices. The implementation of this policy and related procedures will be reviewed, monitored and reported on a regular basis, at least annually. The Company communicates periodically to employees and associated persons on the matter of anti-competitive practices. The implementation of this policy and related procedures will be reviewed, monitored and reported on a regular basis, at least annually.

DATA PROTECTION POLICY

INTRODUCTION

This document sets out the obligations of Links Insurance Brokers LLC (“the Company”) with regard to data protection and the rights of people with whom it works in respect of their personal data.

We are required to maintain certain personal data about individuals for the purposes of satisfying our operational and legal obligations. We recognize the importance of correct and lawful treatment of personal data as it helps to maintain confidence in our organization and to ensure efficient and successful outcomes when using this data.

The types of personal data that we process may include information about current, past and prospective employees, clients and customers, suppliers and other organizations with whom we have dealings. Personal data may consist of data kept on paper, computer or other electronic media. The Company shall ensure that it handles all personal data correctly and lawfully.

This Policy shall set out procedures, which are to be followed when dealing with personal data and is based on the UK’s Data Protection Act (“DPA”) of 1998. The procedures set out herein must be followed by the Company, its employees, contractors, agents, consultants, partners or other parties working on behalf of the Company.

The Company views the correct and lawful handling of personal data as key to its success and dealings with third parties.

THE DATA PROTECTION PRINCIPLES

Any party handling personal data must comply with the DPA’s eight principles set forth below, which states that all personal data:

• 2.1 Must be processed fairly and lawfully (and shall not be processed unless certain conditions are met);
• 2.2 Must be obtained only for specified and lawful purposes and shall not be processed in any manner which is incompatible with those purposes;
• 2.3 Must be adequate, relevant and not excessive with respect to the purposes for which it is processed;
• 2.4 Must be accurate and, where appropriate, kept up-to-date;
• 2.5 Must be kept for no longer than is necessary in light of the purpose(s) for which it is processed;
• 2.6 Must be processed in accordance with the rights of data subjects under the Act;
• 2.7 Must be protected against unauthorized or unlawful processing, accidental loss, destruction or damage through appropriate technical and organizational measures; and
• 2.8 Must not be transferred to a country or territory outside of the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.

RIGHTS OF DATA SUBJECTS

Data subjects have the following rights:

• The right to be informed that their personal data is being processed;
• The right to access any of their personal data held by the Company within 40 days of making a request;
• The right to prevent the processing of their personal data in limited circumstances; and
• The right to rectify, block, erase or destroy incorrect personal data.

PERSONAL DATA

DPA’s definition of personal data is defined as data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, the data controller, and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.

DPA’s definition of sensitive personal data is defined as personal data relating to the racial or ethnic origin of the data subject; their political opinions; their religious (or similar) beliefs; trade union membership; their physical or mental health condition; their sexual life; the commission or alleged commission by them of any offence; or any proceedings for any offence committed or alleged to have been committed by them, the disposal of such proceedings or the sentence of any court in such proceedings.

The Company only holds personal data, which is directly relevant to its dealings with a given data, subject. That data will be held and processed in accordance with the data protection principles and with this Policy. The following data may be collected, held and processed by the Company from time to time:

• Personal address(es)
• Date of Birth
• Marital Status
• Contact information
• Credit card and/or debit card details
• Financial information
• Bank details

PROCESSING PERSONAL DATA

Any and all personal data collected by the Company (including that detailed in Section 4 of this Policy) is collected in order to ensure that the Company can facilitate efficient transactions with third parties including, but not limited to, its customers, partners, associates and affiliates and efficiently manage its employees, contractors, agents and consultants. Personal data shall also be used by the Company in meeting any and all relevant obligations imposed by law.

Personal data may be disclosed within the Company. Personal data may be passed from one department to another in accordance with the data protection principles and this Policy. Under no circumstances will personal data be passed to any department or any individual within the Company that does not reasonably require access to that personal data with respect to the purpose(s) for which it was collected and is being processed.

The Company shall ensure that:

• All personal data collected and processed for and on behalf of the Company by any party is collected and processed fairly and lawfully;
• Data subjects are made fully aware of the reasons for the collection of personal data and are given details of the purpose for which the data will be used;
• Personal data is only collected to the extent that is necessary to fulfill the stated purpose(s);
• All personal data is accurate at the time of collection and kept accurate and up-to-date while it is being held and/or processed;
• No personal data is held for any longer than necessary in light of the stated purpose(s);
• All personal data is held in a safe and secure manner, taking all appropriate technical and organizational measures to protect the data;
• All personal data is transferred using secure means, electronically or otherwise;
• All data subjects can exercise their rights set out above in Section 3.

DATA PROTECTION PROCEDURES

The Company shall ensure that all of its employees, contractors, agents, consultants, partners or other parties working on behalf of the Company comply with the following when processing and/or transmitting personal data:

• Personal data may be transmitted over secure networks only – transmission over unsecured networks is not permitted in any circumstances;
• Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
• Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely;
• Where Personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;
• Where Personal data is to be transferred in hardcopy form it should be passed directly to the recipient. Using an intermediary is not permitted;
• All hardcopies of personal data should be stored securely in a locked box, drawer, cabinet or similar;
• All electronic copies of personal data should be stored securely using passwords and suitable data encryption, where possible on a drive or server which cannot be accessed via the internet; and
• All passwords used to protect personal data should be changed regularly and should not use words or phrases, which can be easily guessed or otherwise compromised.

ORGANIZATIONAL MEASURES

The Company shall ensure that the following measures are taken with respect to the collection, holding and processing of personal data:

• The Operations Manager within the Company shall be appointed with the specific responsibility of overseeing data protection and ensuring compliance.
• All employees, contractors, agents, consultants, partners or other parties working on behalf of the Company are made fully aware of both their individual responsibilities and the Company’s responsibilities and shall be furnished with a copy of this Policy.
• All employees, contractors, agents, consultants, partners or other parties working on behalf of the Company handling personal data will be appropriately trained to do so.
• All employees, contractors, agents, consultants, partners or other parties working on behalf of the Company handling personal data will be appropriately supervised.
• Methods of collecting, holding and processing personal data shall be regularly evaluated and reviewed.
• The Performance of those employees, contractors, agents, consultants, partners or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed.
• All employees, contractors, agents, consultants, partners or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the DPA and this Policy by contract. Failure by any employee to comply with the principles or this Policy shall constitute a disciplinary offence. Failure by any contractor, agent, consultant, partner or other party to comply with the principles or this Policy shall constitute a breach of contract. In all cases, failure to comply with the principles or this Policy may also constitute a criminal offence.
• All contractors, agents, consultants, partners or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy.
• Where any contractor, agent, consultant, partner or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

ACCESS BY DATA SUBJECTS

A data subject may make a subject access request (“SAR”) at any time to see the information which the Company holds about them.

• SAR’s must be made in writing.

Upon receipt of a SAR the Company shall have a maximum period of 40 days within which to respond. The following information will be provided to the data subject:

• Whether or not the Company holds any personal data on the data subject;
• A description of any personal data held on the data subject;
• Details of what that personal data is used for;
• Details of any third-party organizations that personal data is passed to; and
• Details of any technical terminology or codes.

IMPLEMENTATION OF POLICY

This Policy shall be deemed effective as of the 1st of December 2014. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

This Policy has been approved & authorized by:

Name:Simona Kriauciunaite

Position:Operations Manager

Date:1st December 2014

OCCUPATIONAL / WORKPLACE HEALTH AND SAFETY POLICY

INTRODUCTION

Links Occupational / Workplace Health and Safety Policy help to preserve the best possible work conditions for our employees. Every employee has a right to feel safe at work. Our company is committed to follow legal standards and create a hazard-free workplace.

Our Occupational / Workplace Health and Safety Policy help us preserve the best possible work conditions for our employees.

Each employee is encouraged to play a vital and responsible role in maintaining a safe and healthy workplace and caring for our environment through: -

• Being involved in the workplace health, safety & environment system.
• Sticking to correct procedures and equipment use.
• Wearing protective clothing and equipment as and when required.
• Reporting any pain or discomfort as soon as possible. Reporting any pain or discomfort as soon as possible.
• Ensuring all accidents and incidents are reported immediately.
• Helping new employees, trainees and visitors to the workplace understand the right procedures and why they exist.

SCOPE

This Policy applies to all prospective and current employees of the company as well as volunteers, contractors and consultants.

STRONG SAFETY AND HEALTH ORGANISATION

Links believes that accidents are preventable and therefore “one accident is one too many”. We integrate Safety and Health in the management of our business in such a way that all activities are considered with a perspective of prevention of all types of accidents and protection of the people at work. We commit to perform systematic identification of hazards and to manage them with appropriate risk assessments and subsequent actions to minimise danger. We establish emergency and contingency plans to deal with residual risks. This approach also minimises threats to the business.

CONTINUOUS IMPROVEMENT

Our Occupational Safety and Health management system is based on the concept of continuous improvement. We improve constantly our performance by designing and adapting processes, work practices and systems in the direction of better ergonomics and greater safety.

We base our improvement on the monitoring of safety and health performance as well as on the analysis of incidents that produce injuries and of workplace activities whose cumulative effects may lead to illnesses.

LEADERSHIP AND PARTICIPATION

Links recognises the critical role of senior management to ensure a safe and healthy work environment. As an integral part of managing the business, Links’ managers – at all levels – are accountable for managing workplace health and safety with strong leadership and credibility. Respect of safety principles, standards and procedures is a condition of employment. Employees are responsible for working in a safe manner to prevent injury to themselves, fellow workers and other persons. They are asked to become actively involved in programmes to improve health and safety performance in the workplace.

BEHAVIOURAL APPROACH

Preventative action

Preventative action is any action we take to avoid injuries or illness related to workplace conditions.

We conduct periodical risk assessments and job hazard analysis to discover what is likely to harm employees. We establish preventative measures accordingly.

We follow the following preventative measures

• Inspectors and quality control employees inspect equipment and infrastructure regularly
• We regularly hold employee training sessions in health & safety standards and procedures
• Employees who do repairs or cleaning need to put up caution signs
• We prohibit smoking indoors

EMERGENCY MANAGEMENT

Emergency management refers to our plan to deal with sudden catastrophes like fire, flood, earthquake or explosion. These depend on human error or natural forces.

Our emergency management involves the following provisions:

• Functional smoke alarms and sprinklers that are regularly inspected
• Technicians (external or internal) available to repair leakages, damages and blackouts quickly
• Fire extinguishers and other fire protection equipment that are easily accessible
• Fully-stocked first-aid kits at convenient locations

We regularly monitor performance of health and safety procedures and will revise them to ensure higher level of protection.

ADDITIONAL MEASURES

Our company also keep abreast of changes and try to promote health & safety actively. We:

• Update our policy according to changes in occupational health and safety legislation
• Analyze past incidents to discover what went wrong
• Establish clear procedures for accident reporting.
• Revise work procedures to make them safer.

DISCIPLINARY CONSEQUENCES

Every team leader is responsible for implementing this health and safety policy. Employees should follow health and safety instructions and will be held accountable when they don’t. We’ll take disciplinary action that may extend to termination when employees consistently disregard health and safety rules.

It’s everyone’s responsibility to contribute to a healthy and safe workplace.