Complaints Policy

Move Plus are committed to providing a high-quality service to all our clients and customers. When something goes wrong, we need you to tell us about it. This will help us to improve our standards.

If you wish to raise a complaint, please contact us with the details.

The procedure detailed below aims to resolve your complaint within eight weeks, where possible.

What will happen next?

  • We will send you a letter acknowledging receipt of your complaint within three working days of receiving it, enclosing a copy of this procedure.
  • We will then investigate your complaint. This will normally be dealt with by a manager or director who will review your file and speak to the member of staff who dealt with you. A formal written outcome of our investigation will be sent to you within 15 working days of sending the acknowledgement letter.
  • If, at this stage, you are still not satisfied, you should contact us again in writing explaining why. We will arrange for a further, entirely separate review to take place by a senior company director.
  • We will write to you within 14 working days of receiving your request for a review, confirming our final viewpoint on the matter.

If you remain dissatisfied, you can then contact The Property Ombudsman to request an independent review.

 Requesting an independent review

If you are still not satisfied after the last stage of the in-house complaint procedure (or more than 8 weeks has elapsed since the complaint was first made) you can request an independent review from The Property Ombudsman without charge.

The Property Ombudsman
Milford House,
43-55 Milford Street,
Salisbury,
Wiltshire, SP1 2BP.

Tel: 01722 333 306
Email: admin@tpos.co.uk
Web: www.tpos.co.uk

Please note the following: You will need to submit your complaint to The Property Ombudsman within 12 months of receiving our final viewpoint letter, including any evidence to support your case.

The Property Ombudsman requires that all complaints are addressed initially through our in-house complaints procedure, before being submitted for an independent review.

The Property Ombudsman

Move Plus are proud to be a member of The Property Ombudsman scheme which exists to settle disputes between property businesses, such as estate agents, letting agents and property management agents, and consumers.

Find out more about TPO here – http://www.tpos.co.uk/

Terms and Conditions

Please Read These Terms and Conditions Carefully Before Using This Site

Terms of website use

This page (together with the documents referred to in it) sets out the terms of use on which you may use of our website? http://www.move-plus.co.uk (“our site”). Use of our site includes accessing, browsing, or registering to use our site. Please read these terms of use carefully before you start to use our site, as these will apply to your use of our site. By using our site, you confirm that you accept these terms of use and that you agree to comply with them. If you do not agree to these terms of use, you must not use our site.

Other applicable terms

These terms of use refer to our Privacy policy that sets out the terms on which we process any personal data we collect from you or that you provide to us. By using our site, you consent to such processing and you warrant that all data provided by you is accurate.

Changes to these terms

We may revise these terms of use at any time by amending this page. Please check this page from time to time to take notice of any changes we make, as they are binding on you.

Changes to our site

We may update our site from time to time, and may change the content at any time. However, please note that any of the content on our site may be out of date at any given time, and we are under no obligation to update it. We do not guarantee that our site, or any content on it, will be free from errors or omissions.

Accessing our site

Our site is made available free of charge. We do not guarantee that our site, or any content on it, will always be available or be uninterrupted. Access to our site is permitted on a temporary basis. We may suspend, withdraw, discontinue or change all or any part of our site without notice. We will not be liable to you if for any reason our site is unavailable at any time or for any period. You are responsible for making all arrangements necessary for you to have access to our site. You are also responsible for ensuring that all persons who access our site through your internet connection are aware of these terms of use and other applicable terms and conditions, and that they comply with them. Our site is available on a number of different devices and these terms of use shall apply to any device, both current and future. By using our site, you hereby acknowledge and agree that we will not be liable under any circumstances for any damage caused to your device or any software.

Intellectual property rights

We are the owner or the licensee of all intellectual property rights in our site, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved. You may print off one copy, and may download extracts, of any page(s) from our site for your personal use and you may draw the attention of others within your organisation to content posted on our site. Our status (and that of any identified contributors) as the authors of content on our site must always be acknowledged. You must not use any part of the content on our site for commercial purposes without obtaining a licence to do so from us or our licensors. If you print off, copy or download any part of our site in breach of these terms of use, your right to use our site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.

No reliance on information

The content on our site is provided for general information only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on our site. Although we make reasonable efforts to update the information on our site, we make no representations, warranties or guarantees, whether express or implied, that the content on our site is accurate, complete or up-to-date.

Limitation of our liability

Nothing in these terms of use excludes or limits our liability for death or personal injury arising from our negligence, or our fraud or fraudulent misrepresentation, or any other liability that cannot be excluded or limited by English law. To the extent permitted by law, we exclude all conditions, warranties, representations or other terms which may apply to our site or any content on it, whether express or implied. We will not be liable to any user for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with:

  • use of, or inability to use, our site; or
  • use of or reliance on any content displayed on our site.

If you are a business user, please note that in particular, we will not be liable for:

  • pure economic loss, loss of profits, sales, business, contract or revenue;
  • business interruption;
  • loss of anticipated earnings or savings or like loss;
  • loss of business opportunity, goodwill or reputation;
  • wasted management, operational or other time; or
  • any special, indirect or consequential loss or damage.

If you are a consumer (i.e. a private individual, not a business), please note that we only provide our site for domestic and private use. You agree not to use our site for any commercial or business purposes, and we have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity. We will not be liable for any loss or damage caused by a virus, distributed denial-of-service attack, or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our site or to your downloading of any content on it, or on any website linked to it. We assume no responsibility for the content of websites linked on our site. Such links should not be interpreted as endorsement by us of those linked websites. We will not be liable for any loss or damage that may arise from your use of them. Different limitations and exclusions of liability will apply to liability arising as a result of the supply of any services by us to you, which will be set out in our terms of service, available if you hire us.

Viruses

We do not guarantee that our site will be secure or free from bugs or viruses. You are responsible for configuring your information technology, computer programmes and platform in order to access our site. You should use your own virus protection software. You must not misuse our site by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our site. You must not attack our site via a denial-of-service attack or a distributed denial-of service attack. By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately.

Linking to our site

You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it. You must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists. You must not establish a link to our site in any website that is not owned by you. Our site must not be framed on any other site, nor may you create a link to any part of our site other than the home page. We reserve the right to withdraw linking permission without notice. The website in which you are linking must comply in all respects with the content standards expected of a responsible organisation, including compliance with all applicable laws. If you wish to make any use of content on our site other than that set out above, please contact us.

Third party links and resources in our website

Where our site contains links to other sites and resources provided by third parties, these links are provided for your information only. We have no control over the content of those sites or resources.

Applicable law

If you are a consumer, please note that these terms of use, its subject matter and its formation, are governed by English law. You and we both agree that the courts of England and Wales will have non-exclusive jurisdiction. However, if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are resident of Scotland, you may also bring proceedings in Scotland. If you are a business, these terms of use, its subject matter and its formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England.


Privacy Policy including Cookie Policy

Introduction

1.1 We are committed to safeguarding the privacy of visitors to our website; in this policy, we explain how we will handle your personal data.

1.2 By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

How we use your personal data

3.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process;

(b) the purposes for which we may process personal data; and

(c) the legal bases of the processing.

3.2 We may process data about your use of our website (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

3.3 We may process your account data (“account data“). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of providing our services and communicating with you. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.4 We may process information contained in any enquiry you submit to us regarding products and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is consent.

3.5 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

3.6 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject.

3.7 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

Providing your personal data to others

4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.

4.2 In addition to the specific disclosures of personal data set out in this Section 4, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

International transfers of your personal data

5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom.

5.2 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 We will retain and delete your personal data as follows:(a) Account Data will be retained for the duration of our commercial or professional relationship with you or your business. Following the end of any such relationship, we are required to retain this data for a period of at least 6 years to comply with current UK tax legislation.

(b) Enquiry data will be retained for a maximum of 18 months after the date of last contact with you in the instance that we have not subsequently entered into a contract as a result of your enquiry.

(c) Notification Data is retained for as long as you decide to remain subscribed to such services.

6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6.5. We share all purchasers information of both part exchange, assisted sale properties and new build plots with their client house builder. This information is not used for any marketing purposes, but to ensure chain continuity and integrity and is discarded once the transaction is completed. Should you object, please advise us in writing.

Amendments

7.1 We may update this policy from time to time by publishing a new version on our website.

7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

Your rights

8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2 Your principal rights under data protection law are:

  • the right to access;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to object to processing;
  • the right to data portability;
  • the right to complain to a supervisory authority;
  • and the right to withdraw consent.

8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information.

That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee

8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.

8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.10 To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.11 If you feel your personal data has been misused or you feel that we have not kept your personal details secure, you should contact our Data Protection Officer in the first instance to log a complaint.

If you are unhappy with our response or you need any further advice, you should contact the Information Commissioner’s Office (ICO) on the details below:

ICO Helpline
Telephone: 0303 123 1113

The ICO can investigate your claim and take action against anyone who has misused your personal data.

8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.13 You may exercise any of your rights in relation to your personal data by written notice to us.

About cookies

9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies that we use

10.1 We use cookies for the following purposes:

(a) whether your browser can accept cookies – Fasthots may write a test cookie to your browser to check that it can accept cookies for the purposes of logging in. We do not currently host any services on our website that require you to login – Fasthots may however still write this cookie under certain circumstances. The relevant cookie is: Fasthots _test_cookie.

(b) whether you have dismissed the cookie notice banner at the foot of the site – we write a cookie to your browser when you have dismissed this notice to ensure that we do not display it again. This cookie expires 1 month after being set. The relevant cookie is: cookie_notice_accepted.

Cookies used by our service providers

11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website. For example, like many companies, we use analytics to help us monitor our traffic, to get a sense of how many visitors the Website receives every day, the type of individual visiting the website and which sections of the site users typically look at. It’s a key way of knowing how well we’re doing and what we can do better.

11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: http://www.google.com/policies/privacy/?. The relevant cookies are: _ga, _gid & _gat_gtag_UA_4666434_111.3 We pay for advertising from marketing partners on other sites, for example Facebook/LinkedIn. These third parties sometimes require that we put a tiny image (“pixel”) from their site on any landing pages that users might arrive at. These pixels can create cookies for the third party so we can work with them to understand how successful their marketing campaign was. We also need to understand where a user came from, so that, if the user goes on to sign up on our Website, we can pay the correct marketing partner for their service. This website uses retargeting services from the social networks Facebook and LinkedIn. Facebook and LinkedIn collect certain information via cookies to determine which web pages are visited. This data is then used to associate your browser with interest and demographic categories, and serve Facebook and LinkedIn ads based on your past visits to this website. Please note that any information collected by Facebook and LinkedIn via cookies are not linked to any customer’s personal information collected by us.

Managing cookies

12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) http://support.google.com/chrome/answer/95647hl=en (Chrome);

(b) http://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d) http://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) http://support.apple.com/kb/PH21411 (Safari); and

(f) http://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy? (Edge).

12.2 Blocking all cookies will have a negative impact upon the usability of many websites.

12.3 If you block cookies, you may not be able to use all the features on our website.

Our details

13.1 This website is owned and operated by Move Plus.

13.2 We are registered in England under registration number 13833532 , and our registered office is at:

6 Godbolts Business Park, Marks Tey, Colchester, Essex, England, CO6 1HS

13.3 Our principal place of business is at:

6 Godbolts Business Park, Marks Tey, Colchester, Essex, England,  CO6 1HS

13.4 You can contact us:

(a) by post, using the postal address given above;
(b) using our website contact form;
(c) by telephone, on 01206 694060
(d) by email, using info@move-plus.co.uk


Anti Bribery & Anti Corruption

Policy Statement
I1.1 It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate. This includes implementing and enforcing effective systems to counter bribery and corruption.
1.2 We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by UK laws, including the Bribery Act 2010, in respect of our conduct both at home and abroad.

2. ABOUT THIS POLICY
2.1 The purpose of this policy is to:
(a) set out our responsibilities, and of those working for and on our behalf, in observing and upholding our position on bribery and corruption; and
(b) provide information and guidance to those working for and on our behalf on how to recognise and deal with bribery and corruption issues.
2.2 It is a criminal offence to offer, promise, give, request, or accept a bribe. Individuals found guilty can be punished by up to ten years' imprisonment and/or a fine. As an employer if we fail to prevent bribery, we can face an unlimited fine, exclusion from tendering for public contracts, and damage to our reputation. We therefore take our legal responsibilities very seriously.
2.3 We have identified that the following are risks for our business.
In the course of business giving or receiving money, gifts, meals, entertainment or anything else of value as an inducement to a person to do something which is dishonest or illegal.
To address those risks, we have incorporated this policy into our employee handbook and is available to suppliers, contractors and business partners upon request.
2.4 In this policy, "third party" means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.
2.5 This policy does not form part of any employee's contract of employment and we may amend it at any time as it does form part of our employee handbook.

3. WHO MUST COMPLY WITH THIS POLICY?
This policy applies to all persons working for us or any Group Company or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with us, wherever located.

4. WHO IS RESPONSIBLE FOR THE POLICY?
4.1 The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
4.2 The Group HR Manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering bribery and corruption.
4.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy.
4.4 You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions, and queries should be addressed to the Group HR Manager.

5. WHAT ARE BRIBERY AND CORRUPTION?
5.1 "Bribery" is offering, promising, giving, or accepting any financial or other advantage, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage.
5.2 An "advantage" includes money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or anything else of value.
5.3 A person acts "improperly" where they act illegally, unethically, or contrary to an expectation of good faith or impartiality, or where they abuse a position of trust. The improper acts may be in relation to any business or professional activities, public functions, acts in the course of employment, or other activities by or on behalf of any organisation of any kind.
5.4 "Corruption" is the abuse of entrusted power or position for private gain.
Examples:
Offering a bribe: You offer a potential client tickets to a major sporting event, but only if they agree to do business with us.
This would be an offence as you are making the offer to gain a commercial and contractual advantage. We may also be found to have committed an offence because the offer has been made to obtain business for us. It may also be an offence for the potential client to accept your offer.
Receiving a bribe: A supplier gives your nephew a job but makes it clear that in return they expect you to use your influence in our organisation to ensure we continue to do business with them.
It is an offence for a supplier to make such an offer. It would be an offence for you to accept the offer as you would be doing so to gain a personal advantage.
Bribing a foreign official: You arrange for the business to pay an additional "facilitation" payment to a foreign official to speed up an administrative process, such as clearing our goods through customs.
The offence of bribing a foreign public official is committed as soon as the offer is made. This is because it is made to gain a business advantage for us. We may also be found to have committed an offence.

6. WHAT YOU MUST NOT DO
6.1 It is not acceptable for you (or someone on your behalf) to:
(a) give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
(b) give or accept a gift or hospitality during any commercial negotiations or tender process, if this could be perceived as intended or likely to influence the outcome;
(c) accept a payment, gift or hospitality from a third party that you know or suspect is offered with the expectation that it will provide a business advantage for them or anyone else in return;
(d) accept hospitality from a third party that is unduly lavish or extravagant under the circumstances.
(e) offer or accept a gift to or from government officials or representatives, or politicians or political parties, without the prior approval of your director and the Group HR Manager;
(f) threaten or retaliate against another individual who has refused to commit a bribery offence or who has raised concerns under this policy; or
(g) engage in any other activity that might lead to a breach of this policy.

7. FACILITATION PAYMENTS AND KICKBACKS
7.1 We do not make, and will not accept, facilitation payments or "kickbacks" of any kind.
7.2 "Facilitation payments", also known as "back-handers" or "grease payments", are typically small, unofficial payments made to secure or expedite a routine or necessary action (for example by a government official). They are not common in the UK but are common in some other jurisdictions.
7.3 "Kickbacks" are typically payments made in return for a business favour or advantage.
7.4 You must avoid any activity that might lead to a facilitation payment or kickback being made or accepted by us or on our behalf, or that might suggest that such a payment will be made or accepted. If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with your director and the Group HR Manager.

8. GIFTS, HOSPITALITY AND EXPENSES
8.1 This policy allows reasonable and appropriate hospitality or entertainment given to or received from third parties, for the purposes of:
(a) establishing or maintaining good business relationships;
(b) improving or maintaining our image or reputation; or
(c) marketing or presenting our products and/or services effectively.
8.2 The giving and accepting of gifts is allowed if the following requirements are met:
(a) it 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 for favours or benefits;
(b) it is given in our name, not in your name;
(c) it does not include cash or a cash equivalent (such as gift certificates or vouchers);
(d) it is appropriate in the circumstances, taking account of the reason for the gift, its timing and value. For example, in the UK it is customary for small gifts to be given at Christmas;
(e) it is given openly, not secretly; and
(f) it complies with any applicable local law.
8.3 Promotional gifts of low value such as branded stationery to or from existing customers, suppliers and business partners will usually be acceptable.
8.4 Reimbursing a third party's expenses, or accepting an offer to reimburse our expenses (for example, the costs of attending a business meeting) would not usually amount to bribery. However, a payment in excess of genuine and reasonable business expenses (such as the cost of an extended hotel stay) is not acceptable.
8.5 We appreciate that practice varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift, hospitality or payment is reasonable and justifiable. The intention behind it should always be considered.

9. DONATIONS
9.1 We do not make contributions to political parties.
9.2 We only make charitable donations that are legal and ethical under local laws and practices. No donation must be offered or made without the prior approval of your director and the Group HR Manager.

10. RECORD-KEEPING
10.1 We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.
10.2 You must declare and keep a written record of all hospitality or gifts given or received, which will be subject to director review.
10.3 You must submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.
10.4 All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept "off-book" to facilitate or conceal improper payments.
10.5 Records are kept by our Finance Team. You must declare all advantages (see 5.2) received by emailing info@move-plus.co.uk

11. YOUR RESPONSIBILITIES
11.1 You must ensure that you read, understand, and comply with this policy.
11.2 The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
11.3 You must notify your director and the Group HR Manager as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future. For example, if a client or potential client offers you something to gain a business advantage with us or indicates to you that a gift or payment is required to secure their business. Further "red flags" that may indicate bribery or corruption are set out in clause 16.

12. HOW TO RAISE A CONCERN
12.1 You are encouraged to raise concerns about any issue or suspicion of bribery or corruption at the earliest possible stage.
12.2 If you are offered a bribe, or are asked to make one, or if you believe or suspect that any bribery, corruption, or other breach of this policy has occurred or may occur, you must notify your director and the Group HR Manager, as soon as possible.
12.3 If you are unsure about whether a particular act constitutes bribery or corruption, raise it with your director and Group HR Manager.

13. PROTECTION
13.1 Individuals who refuse to accept or offer a bribe, or who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
13.2 We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Group HR Manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the employee handbook.

14. COMMUNICATION
14.1 This policy forms part of the induction process for all individuals who work for us, and regular recognition of its content will be obtained.
14.2 Our zero-tolerance approach to bribery and corruption will be made available to all suppliers, contractors, and business partners upon request.

15. BREACHES OF THIS POLICY
15.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
15.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

16. POTENTIAL RISK SCENARIOS: "RED FLAGS"
16.1 The following is a list of possible red flags that may arise during the course of you working for us and which may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only.
16.2 If you encounter any of these red flags while working for us, you must report them promptly to your director and the Group HR Manager:
(a) you become aware that a third party engages in, or has been accused of engaging in, improper business practices;
(b) you learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a "special relationship" with foreign government officials;
(c) a third party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function or process for us;
(d) a third party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;
(e) a third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business;
(f) a third party requests an unexpected additional fee or commission to "facilitate" a service;
(g) a third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services;
(h) a third party requests that a payment is made to "overlook" potential legal violations;
(i) a third party requests that you provide employment or some other advantage to a friend or relative;
(j) you receive an invoice from a third party that appears to be non-standard or customised;
(k) a third party insists on the use of side letters or refuses to put terms agreed in writing;
(l) you notice that we have been invoiced for a commission or fee payment that appears large given the service stated to have been provided;
(m) a third party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us; or
(n) you are offered an unusually generous gift or offered lavish hospitality by a third party.