1. Purpose

The purpose of this Code of Conduct and Ethics (the “Code”) is to ensure that all employees, contractors, consultants and representatives of Inno Growth Limited (the “Company”) adhere to the highest standards of ethical conduct and professional behaviour. This Code provides guidelines to help individuals act with integrity, accountability, and respect in accordance with UK laws and regulations.

2. Scope

This Code applies to all employees, contractors, consultants, temporary and agency staff, and any other individuals working for or on behalf of Inno Growth Limited.

3. Core Principles.

• Integrity: Act honestly and with integrity in all dealings.
• Respect: Treat all individuals with respect, dignity and fairness.
• Compliance: Comply with all applicable UK laws, regulations and Company policies.
• Accountability: Take responsibility for actions and decisions.
• Confidentiality: Protect confidential information and respect privacy.

4. Conduct Standards.

4.1 Professionalism:

• Perform duties with competence, diligence, and professionalism.
• Maintain a professional appearance and demeanour at all times.
• Avoid conflicts of interest and disclose any potential conflicts to a supervisor or the HR department.

4.2 Respect & Non-Discrimination:

• Treat colleagues, customers, and third parties with respect and without discrimination based on age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, or sexual orientation.
• Foster an inclusive and supportive work environment.
• Do not engage in harassment, bullying, or any form of abusive behaviour.

4.3 Honesty & Integrity:

• Be truthful & transparent in all communications.
• Do not engage in fraudulent or deceptive practices.
• Report any suspected misconduct or unethical behaviour to a supervisor.

5. Confidentiality & Data Protection.

• Protect confidential information and only share it on a need-to-know basis.
• Comply with the Data Protection Act 2018 and General Data Protection Regulation (GDPR) regarding the handling of personal data.
• Do not use confidential information for personal gain.

6. Compliance with Laws & Regulations.

• Adhere to all relevant UK laws and regulations, including those related to anti-bribery, anti-corruption, and anti-money laundering.
• Do not engage in activities that could harm the Company’s reputation or legal standing.

7. Conflict of Interest.

• Avoid situations where personal interests conflict with the interests of the Company.
• Disclose any potential conflicts of interest to a supervisor or the HR department.
• Do not use Company resources or information for personal gain.

8. Use of Company Resources.

• Use Company resources, including time, materials, and equipment, responsibly and for legitimate business purposes.
• Do not engage in unauthorised use or distribution of Company assets.

9. Reporting.

• Report any violations of this Code, unethical behaviour, or illegal activities promptly, whether by its officers, employees, directors, or any third-party doing business on behalf of the Company.
• Employees, officers and directors shall not discharge, demote, suspend, threaten, harass or in any other manner discriminate or retaliate against any individual because of reporting any such violation.
• The Company prohibits retaliation against individuals who report concerns in good faith.

• This Code should not be construed to prohibit from testifying, participating or otherwise assisting in any administrative, judicial or legislative proceeding or investigation.

10. Health & Safety.

• Follow all health and safety policies and procedures to ensure a safe working environment.
• Report any health and safety concerns or incidents to the relevant authority within the Company.

11. Disciplinary Action.

• Violations of this policy may result in disciplinary action, up to and including termination of employment.
• Each case will be reviewed individually, and appropriate action will be determined based on the severity of the violation and the circumstances.

12. Code Review & Updates.

• This Code will be reviewed annually and updated as necessary to ensure its effectiveness and relevance.
• Employees will be notified of any changes to the Code.

13. Acknowledgment.

All employees of Inno Growth Limited are required to acknowledge their understanding and commitment to this Code of Conduct & Ethics.

1. Introduction

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

This policy is based on the UK-GDPR and the ICO’s guidance on the UK-GDPR and also complies with the Data Protection Act 2018, which defines the law of processing data on identifiable living people and most of it does not apply to domestic use. Anyone holding personal data for other purposes is legally liable to comply with this Act, with a few notable exceptions.

This policy applies to all personal information processed by, or on behalf of our Company.

All personal data must be handled and dealt with appropriately however it is collected, recorded and used, and whether it is on paper, in electronic records or recorded in other formats, on other media, or by any other means. It includes information held on computers (including email), paper files, photographs, audio recordings and CCTV images.

The purpose of this policy is to help you understand what personal data our Company collects, why we collect it and what we do with it. It will also help you to identify what your rights are and who you can contact for more information, to exercise your rights or to make a complaint.

1.2  Definitions according to Article 4 of the UK-GDPR

Personal data – any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Data controller – the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data;

Data processor – means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

Processing – any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Personal data breach – a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;

Consent of the data subject – means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

Child – the UK-GDPR defines a child as anyone under the age of 13 years old. The processing of personal data of a child shall be lawful only if and to the extent that consent is given or authorised by the holder of parental responsibility over the child.

Third party – a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;

Filing system – means any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis.

Third country– means a country or territory outside the United Kingdom;

2. Data Protection Policy statement

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

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

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

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

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

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

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

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

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

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

Scope

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

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

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

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

4. Responsibilities and roles under the General Data Protection Regulation

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

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

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

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

4.5 The Legal Compliance Department is the first point of contact for Employees/Staff seeking clarification on any aspect of data protection compliance.

4.6 Compliance with data protection legislation is an obligation for all our Employees/Staff who process personal data.

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

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

5. Data Protection principles

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

Personal data must be processed lawfully, fairly and transparently

Lawfully – you must identify a lawful basis before you can process personal data. These are often referred to as the “conditions for processing”, for example, consent.

Fairly – in order for processing to be fair, the data controller has to make sure that personal data are handled in ways that the data subject would reasonably expect and not use it in ways that have unjustified adverse effects on it.

Transparently – Transparent processing is about being clear, open and honest with people from the start about who you are, and how and why you use their personal data. We ensure that we tell individuals about our processing in a way that is easily accessible and easy to understand. You must use clear and plain language.

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

• the identity and the contact details of the controller and, if any, of the controller’s representative;
• the contact details of the Legal Compliance Department;
• the purposes of the processing for which the personal data are intended as well as the legal basis for the processing;
• the period for which the personal data will be stored;
• the existence of the rights to request access, rectification, erasure or to object to the processing, and the conditions (or lack of) relating to exercising these rights, such as whether the lawfulness of previous processing will be affected;
• the categories of personal data concerned;
• any further information necessary to guarantee fair processing.

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

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

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

The Legal Compliance Department is responsible for ensuring that we do not collect information that is not strictly necessary for the purpose for which it is obtained.

All data collection forms (electronic or paper-based), including data collection requirements in new information systems, must include a fair processing statement or a link to privacy statement and approved by the Legal Compliance Department.

The Legal Compliance Department will ensure that, on an annual basis all data collection methods are reviewed by internal audit to ensure that collected data continues to be adequate, relevant and not excessive.

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

Data that is stored by the data controller must be reviewed and updated as necessary. No data should be kept unless it is reasonable to assume that it is accurate. The Legal Compliance Department is responsible for ensuring that all staff are trained in the importance of collecting accurate data and maintaining it.

Employees/Staff/clients/contractors and third-party providers should be required to notify the Company of any changes in circumstance to enable personal records to be updated accordingly. It is the responsibility of the Company to ensure that any notification regarding change of circumstances is recorded and acted upon.

The Legal Compliance Department is responsible for ensuring that appropriate procedures and policies are in place to keep personal data accurate and up to date, taking into account the volume of data collected, the speed with which it might change and any other relevant factors.

On at least an annual basis, the Legal Compliance Department will review the retention dates of all the personal data processed by our Company, by reference to the data inventory, and will identify any data that is no longer required in the context of the registered purpose. This data will be securely deleted/destroyed in line with the Information Disposal Policy.

The Legal Compliance Department is responsible for responding to requests for rectification from data subjects within one month. This can be extended to a further two months for complex requests. If our Company decides not to comply with the request, the Legal Compliance Department must respond to the data subject to explain its reasoning and inform them of their right to complain to the supervisory authority and seek judicial remedy.

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

Where personal data is retained beyond the processing date, it will be minimised/ encrypted/ pseudonymised in order to protect the identity of the data subject in the event of a data breach. Personal data will be retained in line with the ISP and, once its retention date is passed, it must be securely destroyed as set out in this procedure.

The Legal Compliance Department must specifically approve any data retention that exceeds the retention periods defined in the ISP and must ensure that the justification is clearly identified and in line with the requirements of the data protection legislation. This approval must be written.

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

The Legal Compliance Department will carry out a Data Protection Risk Assessment (DPIA) taking into account all the circumstances of our Company’s controlling or processing operations.

In determining appropriateness, the Legal Compliance Department should also consider the extent of possible damage or loss that might be caused to individuals (e.g., staff or customers) if a security breach occurs, the effect of any security breach on the Company itself, and any likely reputational damage including the possible loss of customer trust.

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

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

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

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

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

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

The UK-GDPR includes provisions that promote accountability and governance. These complement the UK-GDPR’s transparency requirements. The accountability principle in Article 5(2) requires you to demonstrate that you comply with the principles and states explicitly that this is your responsibility.

Our Company will demonstrate compliance with the data protection principles by implementing data protection policies, adhering to codes of conduct, implementing technical and organisational measures, as well as adopting techniques such as data protection by design, DPIAs, breach notification procedures and incident response plans.

6. Personal Data individuals’ rights

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

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

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

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

7. Consent

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

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

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

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

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

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

8. Security of Data

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

8.2 All personal data should be accessible only to those who need to use it, and access may only be granted in line with the Access Control Policy.

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

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

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

9. Disclosure of Data

The Company must ensure that personal data is not disclosed to unauthorised third parties which includes family members, friends, government bodies, and in certain circumstances, the Police. All Employees/Staff should exercise caution when asked to disclose personal data held on another individual to a third party. It is important to bear in mind whether or not disclosure of the information is relevant to, and necessary for the conduct of our Company’s business.

10. Retention and Disposal of Data

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

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

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

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

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

11. Data Transfers

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

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

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

Binding corporate rules

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

Model contract clauses

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

Exceptions

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

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

12. Data Inventory

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

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

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

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

1. Purpose

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

2. Scope

This policy covers all data collected by and stored on the Company owned or leased systems and media, regardless of location. It applies to both data collected and held electronically (including photographs, video and audio recordings) and data that is collected and held as hard copy or paper files. The need to retain certain information may be mandated by federal or local law, federal regulations and legitimate business purposes, as well as the EU General Data Protection Regulation (GDPR).

3. Reasons for Data Retention

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

4. Review

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

5. Retention period for paper records

6. Destruction of records

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

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

Records should be destroyed in the following ways:

7. Audit trail

WHERE TO GO FOR ADVICE AND QUESTIONS

Questions, comments, complaints and requests regarding this policy are welcomed and should be addressed to our office address, Suite 2 34 Market Street, Atherton, Manchester, England, M46 0DN or to our Legal Compliance Department at legal@innogrowth.co.uk.

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

OTHER RELEVANT POLICIES

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

• Data Protection Policy;
• Privacy Policy;
• IT and Communications Systems Policy and any other IT, security and data related policies, which are available on the Portal; and
• Code of Professional & Ethical Conduct.

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

1. Introduction

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

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

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

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

2. Purpose

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

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

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

3. Scope

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

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

4. Definition

4.1. What is a data security breach?

A personal data security breach means “a breach of security leading to the loss, unauthorised destruction, alteration or disclosure of, or access to, personal data transmitted, stored or otherwise processed”.

A data security breach is considered to be any loss of, or unauthorised access to, Company data, normally involving Personal or Confidential information including intellectual property.

Data security breaches include the loss, modification, or theft of data or equipment on which data is stored, inappropriate access controls allowing unauthorised use, human error (e.g. information sent to the incorrect recipient), hacking attacks and ‘blagging’ where information is obtained by deception.

A personal data breach in the context of this procedure is an event or action that has affected the confidentiality, integrity or availability of personal data, either accidentally or deliberately, that results in its security being compromised, and has caused or has the potential to cause damage to the Company and/or the individuals to whom the information relates to.

4.2. What is a data security incident?

A data security incident is where there is the risk of a breach but a loss or unauthorised access has not actually occurred.

It is not always clear if an incident has resulted in a breach; by reporting all perceived data breaches quickly, steps can be taken to investigate, secure the information and prevent the incident becoming an actual breach (e.g. by reporting an email IT can remove the email before it has been read and therefore the data has been contained and not been seen by the incorrect recipient).

For the purposes of this policy, data security breaches include both confirmed and suspected incidents and breaches.

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

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

5. Reporting an incident

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

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

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

6. Containment & Recovery

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

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

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

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

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

7. Investigation & Assessing the Risks

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

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

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

7.4. The investigation will need to consider the following:

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

8. Notification of Breaches

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

8.2. Any notification must be agreed by the management.

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

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

The following will need to be considered:

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

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

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

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

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

8.8 The Investigating Officer will consider whether the Marketing and Communications Team should be informed regarding a press release and to be ready to handle any incoming press enquiries.

8.9. All personal data breaches and actions will be recorded by the Investigating Officer regardless of whether or not they need to be reported to the ICO.

9. Evaluation & Response

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

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

9.3. The review will consider:

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

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

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

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

1. Purpose

Inno Growth Limited (the “Company”) recognises that everyone has a contribution to make to our society and a right to equal opportunity. The purpose of this Policy is to ensure that Inno Growth Limited promotes equality and diversity in the workplace and provides a working environment where all employees are treated with dignity and respect. This Policy outlines Company’s commitment to preventing discrimination and fostering an inclusive culture.

2. Scope

This Policy applies to all employees, contractors, consultants, and any other individuals working for or on behalf of the Company. It covers all aspects of employment, including recruitment, training, promotion, and working conditions.

3. Policy Statement.

Inno Growth Limited is committed to:

• Providing equal opportunities for all employees and job applicants.
• Promoting a culture of respect and inclusion.
• Preventing and addressing any form of discrimination, harassment, or bullying.
• Complying with all relevant equality legislation, including the Equality Act 2010, as amended and in force.

4. Definitions.

4.1 Equality: Ensuring that every individual has an equal opportunity to make the most of their lives and talents, and that no one is treated unfairly or discriminated against.

4.2 Diversity: Recognizing, valuing, and taking account of people’s different backgrounds, knowledge, skills, and experiences, and encouraging and using those differences to create a productive and effective workforce.

5. Responsibilities.

5.1 Management Responsibilities:

• Promote and support the principles of equality and diversity.
• Ensure that this Policy is communicated, understood, and implemented at all levels.
• Monitor compliance with this Policy and take action against breaches.

5.2 Employee Responsibilities:

• Treat colleagues with dignity and respect.
• Report any instances of discrimination, harassment, or bullying.
• Participate in training and development on equality and diversity.

6. Preventing Discrimination.

Company shall not tolerate any form of discrimination based on age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, or sexual orientation. Therefore shall:

• Ensure fair recruitment and selection processes.
• Provide equal access to training, promotion, and career development opportunities.
• Make reasonable adjustments to accommodate the needs of disabled employees.

7. Promoting Diversity.

Company is committed to creating a diverse workforce by:

• Valuing and respecting the different backgrounds and perspectives of employees.
• Encouraging an inclusive environment where everyone feels valued and respected.
• Supporting flexible working arrangements and work-life balance.

8. Addressing Harassment & Bullying.

Harassment and bullying are unacceptable and will not be tolerated. Company shall:

• Provide clear procedures for reporting and addressing complaints.
• Take all complaints seriously and investigate promptly.
• Take appropriate disciplinary action against those who breach this Policy.

9. Training & Awareness.

We will provide training and development to ensure that all employees understand their rights and responsibilities under this Policy. This includes:

• Induction training for new employees.
• Regular refresher training for all employees.
• Specific training for managers and supervisors on handling equality and diversity issues.

10. Monitoring & Review.

We will regularly monitor and review the effectiveness of this Policy to ensure it remains relevant and effective. This includes:

• Collecting and analysing data on the diversity of our workforce.
• Reviewing feedback from employees and stakeholders.
• Making necessary adjustments to improve our approach to equality and diversity.

11. Complaints & Grievances

Employees who believe they have been subjected to discrimination, harassment, or bullying should:

• report their concerns to [HR Department/Supervisor].
• Use Company’s Harassment and Discrimination Policy to report concerns anonymously if necessary.

Complaints will be treated confidentially and investigated in accordance with Company’s grievance procedures.

12. Approval & Acknowledgment.

This Policy has been approved by the senior management of Inno Growth Limited and is effective as of July 2024.

The successful implementation of this Policy depends on the awareness and commitment of all staff members and associates.

All employees of the Company are required to acknowledge their understanding and commitment to this Workplace Equality & Diversity Policy.

 

1. Purpose

The purpose of this Policy is to ensure that Inno Growth Limited (the “Company”) provides a working environment that is free from harassment and discrimination. This Policy outlines our commitment to preventing and addressing any form of harassment and discrimination in the workplace. Harassment and Discrimination Policy applies to all employees, contractors, consultants, and any other individuals working for or on behalf of the Company. It covers all work-related activities, including those occurring on Company premises, during business trips, at work-related social events, and through electronic communications.

2. Policy Statement.

Inno Growth Limited is committed to:

• Providing a workplace where everyone is treated with dignity and respect.
• Preventing and addressing any form of harassment or discrimination.
• Ensuring that all employees understand their rights and responsibilities regarding harassment and discrimination.
• Complying with all relevant UK legislation, including the Equality Act 2010.

3. Definitions.

3.1 Harassment: Unwanted conduct related to a relevant protected characteristic, which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating, or offensive environment.

3.2 Discrimination: Treating someone less favourably because of a protected characteristic, which includes age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.

4. Responsibilities.

4.1 Management Responsibilities:

• Promote a culture of respect and inclusion.
• Ensure that this Policy is communicated, understood, and implemented at all levels.
• Take appropriate action against anyone found to be in breach of this Policy.
• Provide training on harassment and discrimination prevention.

4.2 Employee Responsibilities:

• Treat colleagues with dignity and respect.
• Avoid engaging in any behaviour that could be considered harassment or discrimination.
• Report any instances of harassment or discrimination.
• Participate in training and development on harassment and discrimination.

5. Preventing Harassment & Discrimination.

Inno Growth Limited shall not tolerate any form of harassment or discrimination. To prevent this, the Company shall:

• Implement fair recruitment and selection processes.
• Provide equal access to training, promotion, and career development opportunities.
• Make reasonable adjustments to accommodate the needs of disabled employees.
• Promote awareness and understanding of harassment and discrimination issues.

6. Reporting & Addressing Complaints.

6.1 Employees who believe they have been subjected to harassment or discrimination should:

• Report the incident to their line manager or the HR department as soon as possible.
• Provide details of the incident, including dates, times, and any witnesses.

6.2 All complaints will be treated confidentially and investigated promptly. The investigation process will include:

• A thorough and impartial investigation of the complaint.
• Interviews with the complainant, the alleged harasser, and any witnesses.
• A written report of the findings and any recommended actions.

7. Disciplinary Action.

If the investigation finds that harassment or discrimination has occurred, appropriate disciplinary action will be taken. This may include:

• Formal warnings.
• Suspension or termination of employment.
• Other actions deemed necessary to address the behaviour and prevent recurrence.

8. Support for Affected Employees.

Company shall provide support to employees affected by harassment or discrimination.

This may include:

• Access to counselling services.
• Adjustments to working arrangements.
• Additional training or support as needed.

9. Training & Awareness.

Company shall provide training to ensure that all employees understand their rights and responsibilities under this Policy.

This includes:

• Induction training for new employees.
• Regular refresher training for all employees.
• Specific training for managers and supervisors on handling harassment and discrimination issues.

10. Monitoring & Review.

We will regularly monitor and review the effectiveness of this Policy to ensure it remains relevant and effective.

This includes:

• Collecting and analysing data on reported incidents.
• Reviewing feedback from employees and stakeholders.
• Making necessary adjustments to improve our approach to preventing and addressing harassment and discrimination.

11. Approval & Acknowledgment.

This Policy has been approved by the senior management of Inno Growth Limited and is effective as of July 2024.

The successful implementation of this Policy depends on the awareness and commitment of all staff members and associates. All individuals related to the Company are required to acknowledge their understanding and commitment to this Harassment & Discrimination Policy.

1. Purpose.

The purpose of this Policy is to provide guidelines for the appropriate use of social media and the internet by employees of Inno Growth Limited (the “Company”). This Policy aims to protect the Company’s reputation, ensure the security of company information, and comply with legal and regulatory requirements.

2. Scope.

This Policy applies to all employees, contractors, consultants, and any other individuals working for or on behalf of the Company. It covers all work-related activities conducted on social media and the internet, both during and outside of working hours.

3. Policy Statement.

Inno Growth Limited recognises the importance of social media and the internet as tools for communication, collaboration, and business development. Company encourages their use in a responsible and professional manner that aligns with our values and complies with legal requirements.

4. Definitions

4.1 Social Media: Includes all forms of online communication and platforms, such as Facebook, Twitter, LinkedIn, Instagram, blogs, forums, and any other websites that allow users to create and share content.

4.2 Internet Use: Refers to the use of the internet for browsing, communication, and accessing information, whether for personal or professional purposes.

5. Responsibilities

5.1 Management Responsibilities:

• Promote awareness of this Policy and ensure its implementation.
• Monitor compliance with this Policy and take action against breaches.
• Provide training and support on appropriate use of social media and the internet.

5.2 Employee Responsibilities:

• Use social media and the internet in a manner that reflects well on the company.
• Protect confidential and proprietary information.
• Comply with all relevant laws and regulations.
• Report any concerns or breaches of this Policy.

6. Acceptable Use.

Employees must:

• Use social media and the internet in a manner that does not interfere with their job performance.
• Ensure that their online activities do not harm the reputation of Inno Growth Limited.
• Be respectful and professional in all online communications.
• Use company-provided internet access primarily for business purposes.

7. Prohibited Use.

Employees must not:

• Post or share confidential or proprietary information without authorization.
• Engage in any form of harassment, bullying, or discrimination online.
• Make defamatory, misleading, or false statements about the Company, its employees, or stakeholders.
• Use social media or the internet to conduct illegal activities or violate Company policies.

8. Personal Use of Social Media.

While personal use of social media is generally permitted, employees must:

• Ensure that personal views are clearly stated as their own and not those of Company.
• Avoid posting any content that could negatively impact the company’s reputation.
• Refrain from using Company logos, trademarks, or any other proprietary material without permission.

9. Security & Privacy.

Employees must:

• Protect their online accounts by using strong, unique passwords and enabling security features.
• Be cautious of sharing personal or company information online.
• Report any security breaches or suspicious online activities to the IT department immediately.

10. Monitoring & Compliance.

Company reserves the right to monitor employees’ use of social media and the internet to ensure compliance with this Policy. Any violations of this Policy may result in disciplinary action, up to and including termination of employment.

11. Training & Awareness.

Company shall provide training to ensure that all employees understand their rights and responsibilities under this Policy.

This includes:

• Induction training for new employees.
• Regular refresher training for all employees.
• Specific training for employees who manage official company social media accounts.

12. Review & Updates.

This Policy will be reviewed regularly to ensure its effectiveness and compliance with current laws and regulations. Any updates or changes will be communicated to all employees.

13. Approval.

This Policy has been approved by the senior management of Inno Growth Limited and is effective as of July 2024.

1. Purpose.

Inno Growth Limited (the “Company”) is committed to providing a safe, healthy and productive work environment.

The misuse of drugs and alcohol can impair employee performance, health, and safety, and adversely affect the Company’s operations and reputation.

This Policy outlines our commitment to preventing drug and alcohol misuse and providing support to employees.

This Policy applies to all employees, contractors, consultants, temporary and agency staff, and any other individuals working for or on behalf of the Company within the UK.

2. Definitions.

• Drugs: Any substance that, when taken, has the potential to impair an individual’s physical or mental faculties. This includes illegal drugs, prescription medications (used inappropriately), and over-the-counter drugs.
• Alcohol: Any beverage containing ethanol, including beer, wine, and spirits.
• Under the Influence: A state where an individual’s physical or mental faculties are impaired by drugs or alcohol to the extent that job performance is affected.

3. Policy Statement.

3.1 Prohibited Conduct:

• Possession, use, distribution, or sale of illegal drugs on Company premises or while conducting Company business.
• Reporting to work under the influence of drugs or alcohol.
• Consumption of alcohol or drugs during working hours, including breaks.
• Misuse of prescription or over-the-counter medications.

3.2 Exceptions:

The moderate consumption of alcohol may be permitted at company-sanctioned events or with prior authorisation from senior management, provided it does not impair work performance or pose a safety risk.

4. Responsibilities.

4.1 Employees:

• Must comply with this Policy and report any violations.
• Are encouraged to seek help if they have a drug or alcohol-related problem.
• Must inform their supervisor or HR if they are taking medication that may affect their ability to work safely.

4.2 Managers & Supervisors:

• Must ensure that employees understand and comply with this Policy.
• Should monitor performance and behaviour for signs of drug or alcohol misuse.
• Are responsible for addressing any breaches of this Policy promptly and appropriately.

5. Testing & Searches.

5.1 Drug and Alcohol Testing:

• Inno Growth Limited reserves the right to conduct drug and alcohol testing in the following circumstances:
• Pre-employment screening.
• Post-accident or incident.
• Reasonable suspicion of impairment.
• Random testing, where appropriate.

5.2 Searches:

The Company reserves the right to conduct searches of Company property and premises, including lockers, desks and vehicles, where there is reasonable suspicion of Policy violation.

6. Support & Rehabilitation.

• Employees with drug or alcohol problems are encouraged to seek assistance through the Company’s Employee Assistance Programme (EAP) or through external support services.
• The Company will support employees in accessing treatment and rehabilitation programs and may provide reasonable adjustments during recovery.

7. Disciplinary Action.

• Violations of this Policy may result in disciplinary action, up to and including termination of employment.
• Each case will be considered individually, and the appropriate action will be determined based on the severity of the violation and the circumstances.

8. Confidentiality.

All information regarding drug and alcohol issues will be treated confidentially and disclosed only to those with a legitimate need to know.

9. Review & Monitoring.

• This Policy will be reviewed regularly to ensure it remains current and effective.
• Feedback from employees and stakeholders will be considered in future revisions.

10. Communication.

This Policy will be communicated to all employees, and training will be provided to ensure understanding and compliance.

11. Legal Compliance.

This Policy complies with relevant UK legislation, including the Health and Safety at Work Act 1974 and the Misuse of Drugs Act 1971, as amended and in force.

12. Acknowledgment.

All employees of Inno Growth Limited are required to acknowledge their understanding and commitment to this Drug & Alcohol Policy.

1. Purpose & Statement of Quality Services Policy.

1.1 Inno Growth Limited (the “Company”) is dedicated to providing exceptional service to our customers. The purpose of this Policy is to ensure that the Company consistently provides services that meet or exceed customer expectations and comply with all applicable legal and regulatory requirements. This Policy demonstrates our commitment to quality, continuous improvement, and customer satisfaction and Policy applies to all employees, contractors, consultants, temporary and agency staff, and any other individuals working for or on behalf of Inno Growth Limited within the UK.

1.2 Company is committed to:

• Delivering high-quality services that meet customer requirements.
• Treat all customers with respect and courtesy.
• Provide accurate, clear, and timely information about Company’s services.
• Address customer inquiries and concerns promptly and effectively.
• Continuously improve Company’s services based on customer feedback.
• Providing a framework for setting and reviewing quality objectives.
• Complying with all relevant UK laws, regulations, and industry standards.

2. Customer Service Standards.

2.1 Communication:

• Ensure all customer communications are polite, professional, and informative.
• Respond to customer inquiries within [specified time frame, e.g., 24 hours].
• Use clear and simple language, avoiding jargon.

2.2 Product and Service Information:

• Provide accurate and detailed information about Company’s services.
• Clearly communicate terms and conditions, including prices, warranties, and return policies.

2.3 Accessibility:

• Ensure services are accessible to all customers, including those with disabilities.
• Provide multiple channels for customer interaction (e.g., phone, email, live chat, social media).

3. Customer Feedback.

3.1 Encouraging Feedback:

• Encourage customers to provide feedback on their experience with Company’s services.
• Use surveys, feedback forms, and direct communication to gather customer input.

3.2 Handling Feedback:

• Review and analyse customer feedback regularly.
• Share feedback with relevant departments to drive improvements.
• Communicate any changes or improvements made based on customer feedback.

4. Complaints Handling.

4.1 Complaint Submission:

• Customers can submit complaints through multiple channels (e.g., phone, email, website).
• Ensure the complaint process is simple and accessible.

4.2 Complaint Resolution:

• Acknowledge receipt of complaints within [specified time frame, e.g., 48 hours].
• Investigate and resolve complaints promptly, aiming to provide a resolution within [specified time frame, e.g., 10 working days].
• Keep customers informed of the progress and outcome of their complaints.

4.3 Escalation Process:

• If a customer is not satisfied with the resolution, provide information on how to escalate the complaint.
• Ensure escalated complaints are reviewed by a senior staff member.

5. Responsibilities.

5.1 Management Responsibilities:

• Provide leadership and resources to support the quality Policy.
• Ensure the quality Policy is communicated, understood, and implemented at all levels of the organisation.
• Review the quality Policy regularly to ensure its continued suitability and effectiveness.

5.2 Employee Responsibilities.

• All employees are responsible for delivering excellent customer service and adhering to this Policy.
• Employees must undergo training on customer service standards and complaint handling procedures.
• Employees must report any significant customer feedback or complaints to their supervisor or the customer service department.

6. Quality Management System.

Inno Growth Limited has established a Quality Management System (QMS) to support the implementation of this Policy.

The QMS includes:

• Documented procedures and processes to ensure consistent service delivery.
• Regular audits and assessments to monitor compliance and identify areas for improvement.
• A corrective and preventive action system to address non-conformities and prevent recurrence.
• Mechanisms for collecting and analysing customer feedback to drive improvements.

7. Customer Focus.

Company recognises that success depends on Company’s ability to meet the needs and expectations of customers. To ensure customer satisfaction, Company shall:

• Engage with customers to understand their requirements and expectations.
• Deliver services that meet or exceed customer expectations.
• Address customer feedback and complaints promptly and effectively.
• Continuously seek ways to improve Company services based on customer input.

8. Continuous Improvement.

Company is committed to the principle of continuous improvement, shall:

• Regularly review processes and procedures to identify opportunities for improvement.
• Encourage a culture of innovation and excellence among employees.
• Invest in new technologies and methodologies to enhance service delivery.
• Set measurable quality objectives and track progress towards achieving them.

9. Monitoring & Review.

• Regularly monitor customer service performance through customer feedback and internal audits.
• Review this Policy annually and update it as necessary to ensure its effectiveness.
• Use performance metrics and customer satisfaction surveys to measure compliance with this Policy.

10. Legal Compliance.

Ensure all customer interactions comply with relevant UK legislation, including consumer protection laws and data protection regulations.

11. Confidentiality.

Maintain customer confidentiality and protect personal data in accordance with the General Data Protection Regulation (GDPR).

12. Approval.

This Policy has been approved by the senior management of Inno Growth Limited.

13. Acknowledgment.

All employees of Inno Growth Limited are required to acknowledge their understanding and commitment to this Quality Services Policy.

1. Introduction

Know Your Customer (KYC) Policy is to prevent and mitigate the risks of money laundering, terrorist financing, and other financial crimes. Inno Growth Limited (the “Company”) is committed to ensuring compliance with all relevant UK regulations and international standards.

KYC concerns all employees, contractors, consultants, temporary and agency staff, and any other individuals working for or on behalf of Inno Growth Limited and it covers all customer interactions, including account opening, ongoing monitoring, and transaction processing.

2. Regulatory Framework.

This Policy is based on the following UK and international regulations and standards, as amended and in force:

• The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
• The Proceeds of Crime Act 2002 (POCA).
• The Terrorism Act 2000.
• The Financial Conduct Authority (FCA) guidelines.
• The Joint Money Laundering Steering Group (JMLSG) guidance.
• Relevant EU directives and international standards (e.g., FATF recommendations).

3. Policy Statement.

The Company is committed to:

• Identifying and verifying the identity of customers and beneficial owners.
• Understanding the nature and purpose of customer relationships.
• Conducting ongoing monitoring of customer transactions and activities.
• Reporting suspicious activities to the appropriate authorities.

4. Customer Identification & Verification.

4.1 Customer Due Diligence (CDD):

A. Obtain and verify the following information for individual customers:

• Full name
• Date of birth
• Residential address
• Nationality
• Identification documents (e.g., passport, driving licence)

B. Obtain and verify the following information for corporate customers:

• Company name
• Registered office address
• Business address (if different)
• Nature of business
• Names of directors and beneficial owners
• Identification documents for directors and beneficial owners

4.2 Enhanced Due Diligence (EDD):

A. Apply enhanced measures for high-risk customers, including:

• Politically Exposed Persons (PEPs)
• Customers from high-risk jurisdictions
• Complex ownership structures
• Unusual or large transactions

B. Additional measures may include:

• Obtaining additional identification documents
• Conducting enhanced background checks
• Monitoring transactions more closely

5. Risk Assessment.

5.1 Conduct a risk assessment of each customer based on factors such as:

• Customer type (individual, corporate, PEP)
• Geographical location
• Nature and purpose of the business relationship
• Transaction patterns and volumes

5.2 Assign a risk rating (low, medium, high) and apply appropriate due diligence measures.

6. Ongoing Monitoring.

• Monitor customer transactions and activities on an ongoing basis to detect unusual or suspicious patterns.
• Update customer information and risk assessments regularly.
• Review and analyse transactions against known patterns of money laundering and terrorist financing.

7. Record Keeping.

• Maintain records of all customer identification and verification documents for at least five (5) years after the end of the business relationship.
• Keep records of all transactions and customer interactions for at least five (5) years.
• Ensure records are accessible, secure, and retrievable.

8. Reporting Suspicious Activities.

• Identify and report suspicious activities to the Line Manager.
• The Line Manager will review and, if necessary, file a Suspicious Activity Report (SAR) with the National Crime Agency (NCA).
• Maintain confidentiality and do not disclose the existence of a SAR to the customer.

9. Training & Awareness.

• Provide regular training to employees on KYC procedures, money laundering risks, and reporting obligations.
• Ensure employees are aware of the importance of KYC compliance and the consequences of non-compliance.

10. Policy Review.

• Review this Policy annually and update it as necessary to ensure compliance with changing regulations and standards.
• Incorporate feedback from employees, customers and regulatory authorities in Policy updates.

 

Information Security & Risk Management Policy	Inno Growth Limited
	Updated: 09/2024

1.0 Introduction

Information that is collected, stored, analysed, communicated and reported upon is subject to possible misuse, loss, corruption and theft. To counter this our Organisation implements security measures and controls to protect information based on an assessment of the risk posed. This assessment balances the likelihood of negative business impact versus the resources that are required to implement the controls (and indeed any unintended negative consequences of the controls).

2.0 Purpose

This policy establishes the essential minimum standards for information security that must be met by Inno Growth Limited.

Additionally, the purpose of this policy is to also state the principles our Organisation will use to identify, assess and manage information risk, whilst aligning itself to the overall University of Reading risk management framework.

It permits entities to enhance these security measures based on their unique business requirements and the specific legal and federal guidelines applicable to them, but mandates that they at least meet the security benchmarks outlined herein.

3.0 Objectives

Serving as a foundational document, this policy provides direction for all other security policies and related standards. It outlines the obligation to:

1. Safeguard and uphold the confidentiality, integrity, and availability of information and its supporting infrastructure;
2. Effectively manage the risks associated with security breaches or vulnerabilities;
3. Ensure a secure and reliable information technology (IT) framework;
4. Detect and act upon incidents involving the misuse, loss, or unauthorised access of information assets;
5. Supervise systems for irregularities that may suggest security compromises; and
6. Enhance and promote awareness of information security practices.

Inadequate security measures leading to compromised confidentiality, integrity, and availability of information assets can severely disrupt critical infrastructure operations, financial and business activities, and crucial governmental functions; endanger data; and result in legal and regulatory penalties.

This policy ensures protective measures are adequately implemented to guard the confidentiality, integrity, and availability of information. It also ensures that employees, affiliates and business associates are aware of their responsibilities, possess sufficient understanding of security policies, procedures, and practices, and are informed on how to safeguard information.

4.0 Scope

This information security policy applies to all systems, both automated and manual, over which the entity has administrative control. This includes systems that are managed or hosted by third-party services on the entity’s behalf. It covers all types of information, in any form or format, that are produced or utilised in the course of conducting business activities.

5.0 Statement on Information Security

5.1 Organisational Security Management

1. Effective information security necessitates the establishment of both an information risk management function and an information technology security function. The configuration of the Organisation will determine whether these roles are combined and undertaken by either an individual or a group, or if separate individuals or groups are allocated for each function. It is advised that a senior executive or a team involving senior executives undertake these responsibilities.

Our Organisation has appointed a Chief Information Security Officer (CISO) to oversee risk management. This role entails assessing and providing advice on information security risks and ensuring that:

• The approach to risk for both information assets and specific information systems, including decisions on authorisation, is integrated and aligned with the broader strategic aims and foundational activities of the Organisation;
• The oversight of information assets and the management of risks related to information systems are uniform, mirror the Organisation’s risk appetite, and are evaluated alongside other risk types to guarantee the success of the Organisation’s mission and business operations; and
• The handling of the technical aspects of information security.

1. Decisions regarding information security risk must involve consultations with the functional areas mentioned in section a.
2. While the technical aspect of information security may be outsourced, the ultimate responsibility for the security of its information remains with the Organisation.

5.2 Functional Responsibilities

Executive management is tasked with:

1. Evaluating and accepting entity risks.
2. Defining information security objectives and integrating them into processes.
3. Ensuring the consistent application of security policies and standards.
4. Demonstrating support for security through guidance and resource allocation.
5. Raising security awareness via regular distribution of ISO materials.
6. Managing information classification and protection based on best practices and legal requirements.
7. Overseeing information asset management, including their use and disposal, according to classification.
8. Assigning information owners while retaining overall responsibility for data protection.
9. Engaging in security incident responses.
10. Following breach notification protocols.
11. Complying with legal and regulatory information security obligations.
12. Informing the CISO or the Legal Compliance Department about legal and regulatory demands.
13. Communicating policy and standards requirements, including non-compliance consequences, to employees and third parties, ensuring third party contract compliance.

IT management is tasked with:

1. Guiding and integrating security measures into the data processing and network infrastructure to aid information owners.
2. Allocating resources to uphold information security as per this policy.
3. Establishing and applying security processes, policies, and controls as specified by business needs and this policy.
4. Applying appropriate controls for information based on its classification.
5. Training relevant technical personnel in secure practices.
6. Encouraging the involvement of security and technical staff in safeguarding information assets and selecting efficient security measures.
7. Executing business continuity and disaster recovery plans.

The Chief Information Security Officer (CISO) is tasked with:

 

1. Offering internal security consultation;
2. Formulating and implementing the security strategy and its effectiveness measures;
3. Creating and upholding the Organisation’s security policy and standards;
4. Verifying adherence to these policies and standards;
5. Recommending secure system development practices;
6. Managing incident response and providing expertise;
7. Observing network irregularities;
8. Keeping track of potential external threats like data breaches;
9. Staying connected with security communities and authorities;
10. Alerting to imminent threats and weaknesses;
11. Supplying training materials and conducting awareness programs.

5.3 Duties Separation

1. Implement separation of duties to lower misuse risks. If infeasible, apply alternative controls like activity monitoring and management oversight.
2. Security control audit and approval must stay separate from their implementation.

5.4 IT Asset Management

1. Assign all IT hardware and software to a specific business unit or person.
2. Keep a detailed automated inventory of all hardware and software assets, noting key details like network address, machine name, and software version.
3. Use regular scanning to detect unauthorised hardware/software and alert relevant personnel.

5.5 Cyber Incident Management

1. Organisations must establish an incident response plan with consistent standards for effective security incident response.
2. Any detected or suspected security incidents or vulnerabilities must be promptly reported to the relevant supervisor / upper management and CISO as the designated security representative. Employees concerned about unaddressed cyber security issues can confidentially reach out to the Security Operations Centre.
3. The Security Operations Centre should be alerted to any cyber incidents with potential significant operational or security impacts, or those requiring digital forensics, to ensure appropriate response coordination and oversight.

5.6 Account Management & Access Control

1. Each account needs a designated individual or group for its management, potentially involving both the business unit and IT.
2. Access requires unique user-IDs, unless specified otherwise in the Account Management/Access Control Standard.
3. User-IDs must have an authentication method (e.g., password, biometric) for verifying identity.
4. Systems must lock after inactivity, displaying neutral information (e.g., screen saver), and require re-authentication.
5. Sessions must end automatically under defined conditions as per the standard.
6. Authentication tokens should be confidential and securely protected.
7. Tokens must be securely stored, if at all, with approved methods (e.g., password vault).
8. Information owners decide on access and privileges for their resources.
9. Access is based on job needs, adhering to the principle of least privilege.
10. Privileged account users must have a separate account for general business activities.
11. Systems should display a logon banner stating policy compliance and monitoring.
12. Remote access requires prior approval, risk assessment, and documented controls.
13. Remote connections should occur through managed entry points as per ISO/security guidance.
14. Remote work needs management authorisation and secure data handling training.

5.7 Vulnerability Management:

1. Systems must undergo vulnerability scans before production deployment and regularly after.
2. Regular penetration testing is mandatory for all systems.
3. Critical systems require periodic penetration testing.
4. Outsourced system vulnerability scans and penetration tests must be coordinated.
5. Contracts with third parties must include scan/test and mitigation obligations.
6. Scan/test results are to be promptly reviewed by the system owner and shared with the CISO as the designated security representative for risk assessment.
7. Discovered vulnerabilities must be promptly addressed through actions like patching, with a documented action and milestones plan for mitigation.
8. Only authorised individuals can conduct scans/tests, with prior notification to the CISO as the designated security representative. Unauthorised attempts are prohibited.
9. Authorised testers must adhere to a formal, tested process to avoid disruption.

6.0 Statement on Information Risk Management

1. Systems supporting business must manage information risks and have annual risk assessments within a secure development lifecycle.
2. New projects and major changes require security risk assessments.
3. Entities choose their risk assessment method according to their needs and relevant regulations.
4. Document assessment outcomes and related decisions.

6.1 Risk Assessment

1. Risks are assessed by considering the likelihood of occurrence and the impact a breach of data confidentiality, integrity and/or availability would have if it did occur.
2. Risk assessments shall be completed with appropriate/relevant understanding of and access to:

• The legislation to which the University is subject.
• The technical systems in place supporting the University.
• The impact to the University of risks to business assets.
• The University’s business processes.

1. A risk assessment must be completed (at least) for the following:

• Information assets associated with any proposed new or updated systems.
• Information systems associated with information assets classified as restricted or highly restricted.
• Following the discovery of a new risk impacting a system.

6.2 Threats

The Organisation shall consider all high and critical threats that apply to a system whether deliberate or accidental. Threat information shall be obtained from asset owners, users, incident reviewing, contacts across the sector and region, security consultancies, and local and national law enforcement agencies and security services.

6.3 Vulnerabilities

The Organisation shall consider all high and critical vulnerabilities that apply to a system. Vulnerability information shall be obtained from internal sources (e.g. IT personnel, vulnerability scans etc.), technology providers, contacts across the sector and region, security consultancies, and local and national law enforcement agencies and security services.

6.4 Risk Register

The Impact x Likelihood risk score shall form the basis for the risk register. Risks shall be assigned owners alongside a review date and the risk treatment option/s taking place.

The risk register shall be restricted to those with a need to know.

6.5 Risk Treatment

The treatment option will fall into one or more of the following categories:

Risk avoidance (terminate) – There is no cost-effective action to reduce risk. Deciding not to proceed with activities that introduce unacceptable risk to the University.

Risk sharing (transfer) – Shifting part of the risk to other organisations. Common techniques include insurance and outsourcing.

Risk modification (treat) – Information risks are reduced to an acceptable level by introducing, removing or altering controls.

Risk retention (tolerate) – No additional action is required other than what is already in place.

Risk treatment options shall be selected based on the outcome of the risk assessment, and the expected cost/benefit of implementing the options.

The four options for risk treatment are not mutually exclusive. In some cases, the Organisation may benefit by using a combination of options such as reducing the likelihood of risks, reducing their consequences, and sharing or retaining any residual risks.

6.6 Residual Risk

Once the risk treatment plan has been defined, residual risk/s need to be determined. This involves an update of the risk assessment, taking into account the expected effects of the proposed risk treatment. If the residual risk still does not fall within the Organisation’s acceptable risk criteria, a further iteration of risk treatment may be necessary before proceeding to documented formal sign off via risk acceptance.

6.7 Risk Acceptance

In some cases, it may be necessary to accept risk despite it falling outside of normal acceptable risk parameters. This may be necessary because (for example) the benefits accompanying the risks are very attractive, the cost of risk modification is too high, or because appropriate risk treatment cannot be applied within timeframes defined in policy. In such cases, the risk owner (e.g. information asset owner, system owner etc.) must complete a risk acceptance form that explicitly states the risk/s and includes a justification for the decision to override normal acceptable risk criteria.

Risk acceptance forms shall be reviewed and signed off by a member of the Organisation Directorate or an appropriate equivalent.

Deviation from any information security/cyber security policy shall require risk acceptance. 

7.0 Compliance

This policy becomes active immediately upon publication. All members are required to adhere to the established enterprise policies and standards. These policies and standards are subject to change at any time, and adherence to any revised policies and standards is also required.

Should adherence to this standard be impractical or technically unattainable, or if a departure from this policy is required to facilitate a business function, entities must seek approval for an exception via the Chief Information Security Officer’s exception procedure.

8.0 Contact Information

Submit all inquiries and requests for future enhancements to the Legal Compliance Department which is this policy owner at:

legal@innogrowth.co.uk