Ethics and Standards Policy

ABOUT US

We are a small family-run business with over 25 years of experience in the motor trade. We are ideally placed to offer all our customers a great deal on commercial vehicles supported by excellent customer service.

We take pride in establishing and retaining a trusted client base who can rely on our professionalism and industry knowledge to deliver the service and product they need. As a small business, we take a personal approach to our work and take our relationships and commitment to deliver quality seriously. This Ethics & Standards Policy highlights the standards we promote at SG Motor Holdings and what we expect of anyone working with or for our company.

John Stratton
Director SG Motor Holdings Limited

PURPOSE OF OUR POLICIES

This document defines SG Motor Holding’s (“SG”) policy and corporate approach to ethically delivering a quality service in full compliance with relevant laws and regulations. It is an essential element of our central message: we will act honestly and appropriately when conducting business. This document is the foundation of SG’s governance controls and clarifies the company’s commitment to responsible business.

SCOPE

Our Ethics & Standards Policy (the “Policy”) applies to all individuals working for or on behalf of SG regardless of role, whether full or part-time, temporary or volunteering, including contracted and agency staff.

This document’s standards and corporate messaging also relate to all associated “Third Party” entities that SG deals with, such as advisors, contracts, and suppliers. SG expects all individuals “working for” and those “working with” the company to promote the standards and values set out in this document.

ETHICS & STANDARDS POLICY

OUR HIRE STANDARDS

Our H-I-R-E Standards underpin everything we do. They clarify what we stand for and what SG employees and customers can expect. Anyone not promoting or acting against these standards may be subject to disciplinary action.

HONESTY

We will act openly, transparently, and honestly with our customers, third parties, and staff.

INTEGRITY

We will act in the company’s best interests and avoid any conflicts of interest and where a conflict exists, it is declared and managed.

RESPONSIBILITY

We take responsibility for our behavior and ensure our services are delivered to the highest standard.

ETHICS

We will promote ethical standards of behavior and address risks such as corruption, modern slavery, and data privacy.

STAFF TRAINING & DEVELOPMENT

To ensure SG staff are aware of and discharge the company’s legal responsibilities, SG’s Director will ensure all staff, whether full-time or not, are given appropriate training to ensure they can perform their role to the highest expected standards.

Whether training on specific duties in the van hire specialism or general awareness of essential elements such as GDPR and data management, anti-corruption, and ethics, SG will provide the training needed.

The following training has been identified as essential for staff to undertake, and appropriate training providers will be sourced over the next 12 months:

Essential Training

GDPR/Data Protection
Customer Service
Modern Slavery & Human Trafficking
Anti-Money Laundering
Fraud, cybercrime & Anti-corruption

CORPORATE SOCIAL RESPONSIBILITY (CSR)

CSR refers to how businesses regulate themselves to ensure their activities positively affect society. Our CSR Policy aims to guarantee SG works ethically and considers the social, economic, and environmental impacts of what we do as a business.

INTRODUCTION

We acknowledge that running a business affects society. We are responsible to our customers, employees, and anyone working for or on behalf of SG Motor Holdings and the community in which we operate.

By putting CSR into practice, we are committed wherever possible to:

Conduct ourselves responsibly and ethically, promoting our “HIRE Standards.”
Creating a positive and supportive working environment.
Supporting local communities, whether through donations or support.
Acting reasonably in our dealings with suppliers and other third parties.
Minimizing the impact on our environment with responsible waste disposal.

RESPONSIBILITY

The SG Motor Holdings’ Directors are responsible for our CSR activity, implementing this policy, and ensuring the systems and controls we have in place are effective. We are fully committed to the highest possible standards of Honesty, Integrity, Responsibility, and Ethics (Our “HIRE Standards”).

We encourage all staff members and stakeholders who have serious concerns about any departure from the high standards we set to report it to the Director.

Our conduct

We aim never to act in a way that compromises SG’s integrity. We actively promote respect between our staff members in their dealings with each other, clients, and third parties.

Our Clients

We are committed to delivering a high level of service to all our clients. We understand that our business exists in a very competitive market and to retain our clients, we need to deliver a professional and courteous service.

Our working environment

We recognise that our staff is our most important resource. As a small family business, there is a positive and healthy working environment.

Our Community

Considering our impact on the community, we want to sponsor or support local charities. We will allow members of staff time off work to enable them to carry out work supporting their chosen charity and where possible encourage dialogue with local communities and groups for mutual benefit.

Suppliers

We are committed to eliminating unlawful discrimination and promoting equality and diversity in our dealings with suppliers and other third parties. We endeavour to enter into transparent contracts with our suppliers.

Our Environment

We are committed to behaving responsibly and minimising our environmental impact.

We aim to minimise our impact on the environment by:

Minimising waste and adopting sensible recycling policies regarding paper and food consumption.
Providing safe and comfortable working conditions.
Ensuring that electrical equipment and lights are off when not in use.
Ensuring that heating is turned off or down outside office hours.
Responsibility for this policy, including an annual review to ensure it remains current, compliant, and relevant to the organisations and its clients’ needs.
Verify it is in effective operation across the practice.

MODERN SLAVERY & HUMAN TRAFFICKING

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain. This statement is made under section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking policy.

OUR COMMITMENT

SG has a zero-tolerance approach to Modern Slavery and Human Trafficking. We are committed to acting ethically and with integrity in all our business dealings and relationships to ensure it is not happening anywhere in our business or supply chains. We expect the same high standards from anyone working with or for SG, including suppliers and contractors.

RESPONSIBILITIES

The Company Director is responsible for ensuring this policy complies with our legal and ethical obligations. All SG staff must read, understand, and adhere to this policy.

RED FLAGS (WARNING SIGNS)

Someone in slavery might:

Appear to be under the control of someone else and reluctant to interact with others
Have few personal belongings, wear the same clothes every day, or wear unsuitable clothes for work
Not be able to move around freely and they may not have access to personal identification.
Appear frightened or withdrawn or show signs of physical or psychological abuse.

REPORTING CONCERNS

Police on 999 if someone may be in immediate harm.
Call the Modern Slavery Helpline on 08000 121 700 or complete an online form.
Gangmasters and Labour Abuse Authority to report concerns about the mistreatment of workers on 0800 432 0804 or by email at intelligence@gla.gov.uk
Crimestoppers on 0800 555 111
Contact Anti-Slavery International.

COUNTER FRAUD BRIBERY & CORRUPTION POLICY

SG Motor Holdings does not tolerate any form of fraud, bribery, or corrupt practice.

FRAUD

The Fraud Act 2006 relates to dishonestly and intentionally making a false representation, failing to disclose information when legally bound to do so, abusing their position to gain for themselves or another, causing loss to another or exposing another to loss.

CORRUPTION

The word “corruption” is an umbrella term for a range of dishonest, unethical, and potentially criminal acts committed by those working for or with an organisation. It is widely considered to be “the abuse of entrusted power for private gain.”

Corrupt behaviour includes:

Theft of SG property.
Misusing assets (vehicles, fuel cards) for personal use.
Disclosing sensitive commercial information to third parties.
Accessing files or digital records without authority.

BRIBERY

Bribery is illegal and carries a prison sentence of up to 10 years. It is governed by the Bribery Act 2010. The Act contains two general offences covering the offering, promising, or giving of a bribe (section 1) and the requesting, agreeing to receive, or accepting of a bribe (section 2).

It also sets out two further offences which specifically address commercial bribery. Section 6 creates an offence relating to bribery of a foreign public official to obtain or retain business or an advantage in business conduct. Section 7 creates corporate liability for failing to prevent bribery on behalf of a commercial organisation.

Examples of bribery:

A Director uses a facilitator to pay the procurement manager of another business money to secure a contract with them.
A Director accepts a bribe for passing on sensitive information about contracts with other businesses to undercut their pricing (section 2 offence).

SG employees must not:

Give, promise to give, or offer a payment, gift, or hospitality with the expectation or hope that a business advantage will be received or reward a business advantage already given.
Give, promise to give, or offer a payment, gift, or hospitality to a Public Official or Third Party to ‘facilitate’ or expedite a routine procedure.
Accept payment from a Third Party that you know or suspect offered with the expectation that it will obtain a business advantage for them.

Reporting concerns

Directors of SG know that should they have any concerns about corrupt practices or bribery, they can report it to law enforcement agencies including the police, Serious Fraud Office, Competitions & Marketing Agency, or financial regulators.

GIFTS & HOSPITALITY

SG employees are prohibited from accepting a gift or giving a gift to a third party in the following situations:

When it is made to influence a Third Party to obtain or retain business, gain a business advantage, reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits.
It is of an inappropriate type and value and given at the wrong time, e.g., during a tender process.
It is given secretly and not openly.

THE COMPETITION ACT 1998

Competing fairly is vital. The Competitions Act primarily prohibits agreements or understandings between competitors and non-competitors that are likely to prevent or restrict competition.

It prohibits “abusive” practices by any business which acts without regard to its customers, competitors, or suppliers.

COMPLAINT HANDLING POLICY

SG aims to provide a high standard of service to every client. It is important to us that all complaints are resolved quickly and where possible to the satisfaction of our clients.

The following process explains how we deal with complaints, our commitments to you, and what remedy you have if you think your complaint still needs to be resolved to your complete satisfaction.

IF YOU HAVE A COMPLAINT

We would like to hear from you if you have a complaint about any aspect of our service. You can contact us by telephone, e-mail, or in writing, and the Directors will try to resolve your complaint.

To resolve your complaint efficiently, please provide the following information:

Your full name and preferred contact details
Full details of your complaint
Copies of any relevant paperwork
Photographic evidence of any complaint relating to vehicle damage/defects where applicable
Any other information that you think may be relevant.

Please note: If you appoint a third party to act on your behalf, we can only discuss any aspect of your contract with them once we receive your permission in writing or from your email address.

We will try to resolve your complaint immediately; however, this may be impossible sometimes. In the unlikely event that we cannot resolve your complaint by the end of the next business day, we will keep you informed of the progress of our investigations and provide our final response in writing providing our findings and the action to take.

CONTACT US

E-mail: sales@sgmotorholdings.com
Phone: 0151 372 6728
Write: SG Motor Holdings Limited, Bank Farm, Ledsham Lane, Ellesmere Port, CH66 0NA

ELIGIBILITY

It is SG policy to treat all complaints properly. However, certain types of complaints may fall within the scope of FCA rules and consequently within the jurisdiction of the Financial Ombudsman Service.

COMPLAINT PROCEDURE

We will acknowledge your complaint usually within three working days via e-mail or letter.
Fully investigate your complaint.
Keep you informed of any progress.
We will aim to send you our final written response within ten working days but no later than eight weeks as required by the Financial Conduct Authority.

FINAL RESPONSE

This will set out SG’s decision and the reasons for it. If any compensation is offered, a clear method of calculation will be shown. Where appropriate, we must include details of the Financial Ombudsman Service in the final response. If dealing with an eligible complainant and a regulated activity, we will:

Explain that the complainant must refer the matter to the Ombudsman within six months of the date of this letter or the right to use this service is lost.

IF YOU ARE NOT HAPPY WITH OUR DECISION

THE FINANCIAL OMBUDSMAN

If you have a regulated contract with us and are unsatisfied with our final response, you may be eligible to refer the matter to the Financial Ombudsman Service. You must do this within six months of our final response. When we send you our final response, we will provide you with a copy of the Financial Ombudsman Service’s explanatory leaflet found here.

SG Motor Holdings Limited is authorised and regulated by the Financial Conduct Authority. Our reference number is 753860.

You can verify this on the Financial Conduct Authority’s Register by visiting the Financial Conduct Authority’s website: http://www.fca.org.uk/register/ or by contacting them on 0300 500 8082.

The Financial Conduct Authority does not regulate other services we offer; however, the Financial Ombudsman Services has now been extended to handle some complaints under the Consumer Credit Act.

The Financial Ombudsman Service, Exchange Tower, London E14 9SR

Tel: 0800 023 4567 (free for most people from a fixed line) or 0300 123 9123 (cheaper for those calling using a mobile) or 020 7964 0500 (if calling from abroad).
Email: complaint.info@financial-ombudsman.org.uk
Website: www.financial-ombudsman.org.uk

DATA USE & PRIVACY POLICY

COLLECTING AND USING YOUR DATA

The General Data Protection Regulations 2018 (GDPR) enhance the degree of protection that members of the public can expect from all bodies who hold or process data about them if that data “relates to a living individual who can be identified from it.”

SG Motor Holdings Limited is both a data controller and a data processor. We both hold information about you and use it in various ways including the possibility of making decisions about what we do because of information drawn from analysing the data we hold on individuals. We, therefore, both have and process your data and are governed by GDPR.

DATA CONTROLLER & PROCESSOR

For any inquiries or requests about your data, please contact:

E-mail: sales@sgmotorholdings.com
Phone: 0151 372 6728
Write: SG Motor Holdings Limited, Bank Farm, Ledsham Lane, Ellesmere Port, CH66 0NA

LAWFUL PROCESSING

It is lawful for us to process personal information about you in different circumstances as follows:

Where we process personal information about you to fulfil any order you place with us or otherwise to perform our contract with you
For any purpose that you have consented to where we have asked for your consent in the box that pops up when you first visit our Site and/or as part of the ordering process
Where we are required to do so to comply with our legal obligations such as preventing money laundering and safeguarding against fraud; and
Where we have a legitimate interest in processing your personal information. We have a legitimate interest where we may contact you about products or services, market to you, or collaborate with others to improve our services.

CONSENT

Where you have given us consent to use your personal information in any way you have a right to withdraw that consent at any time. If you withdraw your consent this does not affect the lawfulness of our processing activities carried out before such withdrawal. If you would like to withdraw your consent please get in touch with us. By visiting our Site you consent to our use of your data in the manner described in that privacy notice (as explained further in this Privacy Policy as amended from time to time).

You also consent to the placement by use of cookies on your access device, the cookies being used for the purposes set out in this Privacy Policy and which may contain personal information about you.

PERSONAL DATA WE COLLECT

Name, address, telephone number (including mobile phone) and email.
The information included in any documents you send to us (such as your driving licence and passport) or when using our Site (including via your customer portal if you use one) including to search for hire vehicles, place orders, or report problems with the Site or an order.
Information you complete about customer satisfaction surveys.
Your occupation or the nature of your business (if applicable).
Details about the vehicle to be hired or purchased.
Bank details including the account number and sort code, debit, and credit card numbers.
Information obtained by credit reference agencies (further information is set out below).
Information provided to us by third parties we work with (such as business partners and brokers, sub-contractors in technical payment and delivery services, advertising networks, analytics providers, and search information providers). We will notify you when we receive information about you from them and the purposes for which we intend to use that information if different from the purposes set out in this Policy.
Details about your marketing preferences and interests; debit or credit card details or the bank account details from which direct debits under your vehicle hire will be collected.

WEBSITE USAGE DATA ABOUT YOU

Technical information including the Internet protocol (IP) address used to connect your computer to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform.
Information about your visit including the full Uniform Resource Locators (URL), clickstream to, through, and from our Site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.

TRACKING TECHNOLOGIES AND COOKIES

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies are beacons, tags, and scripts to collect and track information and improve and analyze our service. The technologies We use may include:

Cookies or Browser Cookies: A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a cookie is being sent. However, if You do not accept Cookies, you may be unable to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse cookies, our Service may use Cookies.

HOW YOU CAN MANAGE YOUR COOKIES

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:

Blocking all cookies will have a negative impact on the usability of many websites. If you block cookies you cannot use all the features on our website.

DATA SECURITY

We have appropriate technical and security measures to prevent unauthorised or unlawful access to, or use of, accidental loss of, or destruction, or damage to your information. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Site, you are responsible for keeping this password confidential. You are responsible for preventing unauthorised access to your password and computer, and we ask you not to share a password with anyone.

We limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know (see “sharing with third parties” below). They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, including by taking security measures in accordance with applicable data protection law, we cannot guarantee the security of your data transmitted to our Site. Once we have received your information, we will use strict procedures and security features to protect it.

TRANSFERRING YOUR DATA

By submitting your personal data, you agree to this transfer, storage, or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and in accordance with the appropriate safeguards as required by relevant data protection law, including:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
Where we use certain service providers, we may use specific contracts approved by the European Commission, which give personal data the same protection it has in Europe; and
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between Europe and the US.

We will not sell, distribute, or lease your personal information to third parties unless we have your permission or are required by law to do so. We may pass personal information to people who process data for us. We may pass details about you to our agents and subcontractors to help us with any of our uses of your data set out in this Privacy Policy; for example, we may use third parties to assist us with providing the administration for running our Site, to analyze data, and to provide us with marketing or customer service assistance.

We may also share your personal information with:

Law enforcement agencies, regulatory bodies, and other third parties (including but not limited to the Driver and Vehicle Licensing Agency) if we are under a duty to disclose or share your personal information to comply with any legal obligation (including but not limited to in connection with a court order); to enforce our website terms of use or our terms and conditions of hiring vehicles or any other agreement we have with you; or to protect the rights, property, or safety of us, our customers, or others;
Our insurers to comply with our insurance obligations.
Professional advisors and debt collection agencies to assist with the recovery of amounts owed to us by you or the organisation you represent under any agreement between you and us.
Credit reference agencies (for further information see the Credit Reference Check Policy below).
As stated above, we may commercially exploit any anonymised or aggregated information on the basis that no individuals are identified or identifiable.

VEHICLE TRACKING DEVICES AND THEIR DATA

We may install devices in your vehicles which track the whereabouts of the vehicle and provide other information about the vehicle (including for example the way it is driven). These devices are supplied directly by a third party. If you are unclear as to the basis on which tracking devices are supplied, please contact us using the details below or contact the relevant account customer.

We may disclose tracking information collected by these devices to the relevant hire or fleet management customer and to law enforcement agencies, regulatory bodies, and other third parties.

THIRD PARTY WEBSITES

Our site may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites, and such websites are not governed by this Privacy Policy. You should exercise caution and look at the privacy policy applicable to the website in question.

Communication engagement and actions taken through external social media platforms on which we may participate are subject to the terms, conditions, and privacy policies held by each social media platform respectively. We will never ask for personal information through social media platforms and we encourage users wishing to discuss sensitive details to contact us through primary communication channels such as by telephone or email.

Our site may use social sharing buttons which help share web content directly from web pages to the social media platform in question. You are advised before using such social sharing buttons that you do so at your own discretion and note that the social media platform may track and/or save your request to share a web page through your social media platform account.

YOUR DATA PROTECTION RIGHTS

Under data protection law, you have rights including:

Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
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 personal information in certain circumstances.
Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation or to you in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

DATA RETENTION PERIOD

Personal information will be stored only for so long as we continue to need it, which will vary depending on the nature of the information and the purposes for which we are processing it. Any information we hold will be protected by the terms of this Data & Privacy Policy and once no longer required and we have no further legitimate reason to retain it, it will be securely destroyed.

CREDIT REFERENCE AGENCIES

In order to process your application, we will supply your personal information to credit reference agencies (CRAs), and they will give us information about you such as your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts, and prevent criminal activity. We will also continue to exchange information about you with CRAs on an ongoing basis, including your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. The identities of the CRAs we use and the ways in which they use and share personal information are explained in more detail: Creditsafe

HOW TO COMPLAIN

If you have any concerns about our use of your personal information, you can make a complaint to us at:

E-mail: sales@sgmotorholdings.com
Phone: 0151 372 6728
Write: SG Motor Holdings Limited, Bank Farm, Ledsham Lane, Ellesmere Port, CH66 0NA

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane, Wilmslow
Cheshire, SK9 5AF

Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

ETHICS & STANDARDS POLICY

SG MOTOR HOLDINGS LTD

E-mail: sales@sgmotorholdings.com
Phone: 0151 372 6728
Write: SG Motor Holdings Limited, Bank Farm, Ledsham Lane, Ellesmere Port, CH66 0NA