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Pattonair Disclosures

PATTONAIR MODERN SLAVERY & HUMAN TRAFFICKING STATEMENT 2018

Introduction

We are committed to improving our practices to combat slavery and human trafficking. This statement sets out our current practices as well as our aims for the future showing our commitment to supporting our stakeholders, customers, employees and our supply chain to eradicate slavery and human trafficking globally.

Organisation structure

We are a worldwide supply chain organisation headquartered out of Derby, UK. We offer a global service that is flexible to suit the needs of each customer with unparalleled delivery levels within the aerospace sector; both civil and defence.

Our business operates across the world in multiple locations supporting a global customer base. We have circa 1000 employees that support on a 24/7 basis all year round. Our main facilities are based in the UK, US, France, Poland and Singapore.

This statement is made by Pattonair (Holdings) Limited on behalf of the entire Pattonair group (including, without limitation, Pattonair (Derby) Limited and Pattonair Limited in the UK).

Our business

The supply chain we operate in mainly deals in ‘C class’ components. These are defined as high volume and low cost in nature. Our business model allows us to manage the supply chain for our customers because we have extensive relationships with numerous manufacturers globally, giving us access to a wide range of products. Our high quality standards and approval system allows for faster, more efficient and cosT effective aerospace product distribution.

Our supply chain

Our supply chain includes suppliers that we manage directly and those that we deal with on behalf of our customers. Our global spend on suppliers is over £250 million per annum. Our supply chain is complex but mainly centred in Europe and USA. We are conscious of the fact that our suppliers present the greatest potential exposure to modern slavery and we therefore have risk assessment processes in place to understand and minimise such risk.

When engaging with a supplier, we carry out appropriate due diligence, such as checking whether there have appropriate policies and procedures in place to deal with modern slavery. To improve and formalise this process, we will be amending our new supplier assessment form to include appropriate checks on modern slavery.

We run a Gold programme for suppliers – this is for the suppliers who are strategic partners for the business and with whom the main volume of our spend is placed. Such strategic suppliers are subject to our Vendor Appraisal and Ranking (VAR) criteria. As part of this, checks are made to ensure that suppliers have policies and procedures in place to demonstrate their awareness of and compliance with modern slavery legislation.

We also intend to issue a due diligence questionnaire focussing on the issue of modern slavery. This will be issued to our Gold programme suppliers in the first instance, which will capture the vast majority of Pattonair supplier spend. This will also be sent out to suppliers in higher risk jurisdictions and those going through the new supplier assessment. The results will be analysed and an appropriate action plan developed thereafter.

Members of our strategic procurement team frequently visit suppliers. They have undergone training to make them aware of signs that they need to look out for. We are conscious that a growing number of suppliers are based in low cost regions and have made our strategic procurement staff aware of the associated risks of this.

If any supplier is unable to comply with our supplier standards, including those regarding slavery and human trafficking, we will take appropriate action. This may include the cancellation of purchase orders as well as alerting local authorities of any suspected or confirmed illegal activity.

Our policy on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business.

In light of the obligation to report on measures to ensure that all parts of our business and supply chain are slavery free we have reviewed our workplace policies and procedures to assess their effectiveness in identifying and tackling modern slavery issues.

Our workplace policies and procedures demonstrate our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls, so that to the best of our ability, slavery and human trafficking is not taking place anywhere in our supply chain.

We have also issued our Code of Conduct to all employees and the supply chain. This makes it clear that the group will not condone the use of forced labour.

To strengthen this, we will also be putting in a place a specific Modern Slavery Policy to raise awareness of the issue across the business, educate the business on possible indicators of modern slavery and remind the business of the process for notifying concerns.

Training

We have rolled out training to our strategic procurement team to raise awareness of the company’s obligations under the Act and what constitutes modern slavery and to provide signs to look out for. This will be further supported by the Modern Slavery Policy. Training will be rolled out further across the company as appropriate.

Update since the 2017 Modern Slavery Statement

Training on modern slavery and the signs to look out for has been rolled out to the strategic procurement team. A Modern Slavery Policy has been drafted and a supplier due diligence questionnaire is being drafted.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (UK) and the Trafficking Victims Protection Act of 2000 (USA), and constitutes Pattonair’s slavery and human trafficking statement for the financial year 2018.

Approved by the board of Pattonair Holdings Limited on 21 March 2019

Wayne Hollinshead

CEO

Date: 29 March 2019


PATTONAIR MODERN SLAVERY STATEMENT 2017

Introduction

We are committed to improving our practices to combat slavery and human trafficking. This statement sets out our current practices as well as our aims for the future showing our commitment to supporting our stakeholders, customers, employees and our supply chain to eradicate slavery and human trafficking globally.

Organisation structure

We are a worldwide supply chain organisation head quartered out of Derby, UK. We offer a global service that is flexible to suit the needs of each customer with unparalleled delivery levels within the aerospace sector; both civil and defence.

Our business operates across the world in multiple locations supporting a global customer base. We have circa 1000 employees that support on a 24/7 basis all year round. Our main facilities are based in the UK, US, France and Singapore.

This statement is made by Pattonair (Holdings) Limited on behalf of the entire Pattonair group.

Our business

The supply chain we operate in mainly deals in ‘C class’ components. These are defined as high volume and low cost in nature. Our business model allows us to manage the supply chain for our customers because we have extensive relationships with numerous manufacturers globally, giving us access to a wide range of products. Our high quality standards and approval system allows for faster, more efficient and cost effective aerospace product distribution.

Our supply chain

Our supply chain includes direct and indirect suppliers. Our global spend on suppliers is over £200 million per annum. Our supply chain is complex but mainly centred in Europe and USA. Our approach to risk assessing our supply chain is based up on a number of measures namely:

Size of company

Location

Labour practices

Code of Conduct and compliance

To enable this assessment Pattonair is/will be:

Carrying out appropriate due diligence when engaging with a supplier – such as checking whether they have appropriate policies in place to deal with modern slavery;

Providing suppliers with copies of our Code of Conduct;

Providing internal e-learning to relevant employees, particularly those who deal with suppliers; and

Issuing a Supplier Memorandum to bring the issue of modern slavery to the attention of the supply chain and to enforce the fact that Pattonair has zero tolerance for modern slavery or human trafficking in it business or supply chain.

Our policy on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business.

In light of the obligation to report on measures to ensure that all parts of our business and supply chain are slavery free we have reviewed our workplace policies and procedures to assess their effectiveness in identifying and tackling modern slavery issues.

Our workplace policies and procedures demonstrate our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls, so that to the best of our ability, slavery and human trafficking is not taking place anywhere in our supply chain.

Due diligence process

As part of our initiative to identify and mitigate risk we are putting in place systems to:

Identify and assess potential risk areas in our supply chain;

Mitigate the risk of slavery and human trafficking occurring in our supply chain; and

Monitor potential risk areas in our supply chain.

Supplier adherence to our values

The company has issued its Code of Conduct to all employees and the supply chain. This makes it clear that the group will not condone the use of forced labour.

As part of our Vendor Appraisal and Ranking (VAR), checks are made to ensure that suppliers have policies and procedures in place to demonstrate their awareness of and compliance with modern slavery legislation.

If any supplier is unable to comply with our supplier standards, including those regarding slavery and human trafficking, we will take appropriate action. This may include the cancellation of purchase orders as well as alerting local authorities of any suspected or confirmed illegal activity.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we intend to provide training to senior management and staff involved in the supply chain to ensure that they are best placed to identify any modern slavery issues and understand the steps that need to be taken in the event that they have concerns.

We have rolled out an updated Whistleblowing Policy, which staff are free to use if they have any concerns about the manner in which Pattonair or any of its customers or suppliers do business and which they do not feel comfortable to raise using traditional channels.

Update since the 2016 Modern Slavery Statement

A new Whistleblowing policy was made available to all staff and we are pleased to report that we have received no reports of any matters linked to modern slavery.

Our Code of Conduct has been provided to our supply chain and it has been made clear that compliance with this is required in order to continue to work with Pattonair.

We continue to work with our supply chain through the VAR process to manage the risk of modern slavery and intend to develop diligence in this area over the coming twelve months.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (UK) and the Trafficking Victims Protection Act of 2000 (USA), and constitutes Pattonair’s slavery and human trafficking statement for the financial year ending 2017.

Wayne Hollinshead

CEO

PATTONAIR MODERN SLAVERY STATEMENT 2016

Introduction

We are committed to improving our practices to combat slavery and human trafficking. This statement sets out our current practices as well as our aims for the future showing our commitment to supporting our stakeholders, customers, employees and our supply chain to eradicate slavery and human trafficking globally.

Organisation structure

We are a worldwide supply chain organisation head quartered out of Derby, UK. We offer a global service that’s flexible to suit the needs of each customer with unparalleled delivery levels within the aerospace sector; both civil and defense.

Our business operates across the world in multiple locations supporting a global customer base. We have circa 1000 employees that support on a 24/7 basis all year round. Our main facilities are based in US, UK, France,

Our business

The supply chain we operate in mainly deals in ‘C class’ components. These are defined as high volume and low cost in nature. Our business model allows us to manage the supply chain for our customers because we have extensive relationships with numerous manufacturers globally, giving us access to a wide range of products. Our high quality standards and approval system allows for faster, more efficient and cost effective aerospace product distribution.

Our supply chain

Our supply chain includes direct and indirect suppliers. Our global spend on suppliers is over £200 million per annum. Our supply chain is complex but mainly centred in Europe and USA. Our approach to risk assessing our supply chain will be based up on a number of measures fundamentally considering:

Size of company

Location

Labour practices

Code of ethics and compliance

To enable this assessment Pattonair will be:

Providing internal e-learning to all employees

Issuing a Compliance Questionnaire as part of its due diligence programme to assess the current state and future requirements of the supply chain

Holding awareness workshops at future supplier conferences.

Our policy on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

In light of the obligation to report on measures to ensure that all parts of our business and supply chain are slavery free we have reviewed our workplace policies and procedures to assess their effectiveness in identifying and tackling modern slavery issues.

Our workplace policies and procedures demonstrate our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls, so that to the best of our ability, slavery and human trafficking is not taking place anywhere in our supply chains. Supporting this is our published Corporate responsibility report for financial year 2016

Due diligence process

As part of our initiative to identify and mitigate risk we are putting in place systems to:

Identify and assess potential risk areas in our supply chains

Mitigate the risk of slavery and human trafficking occurring in our supply chains

Monitor potential risk areas in our supply chains

Protect whistle blowers

Supplier adherence to our values

A revised Code of Ethics is in development which will be applicable for all employees and suppliers alike. The aim is to publish this by October 2016.

Currently our Vendor Appraisal and Ranking (VAR) covers ethical conduct but not to the extent we believe it should to exceed compliance standards. As part of the risk assessment and supply chain mapping exercise that we will conduct on our vendors we will understand the level of compliance they adhere to currently and support with plans to improve. The vendor risk assessment will be completed by March 2017.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we intend to provide training to our staff. We will require our business partners to provide training to their staff and suppliers and providers. During financial year 2016 we commenced using on-line training solutions for a number of initiatives. Awareness training for employees on slavery and human trafficking as an on line package will be rolled out during financial year 2017.

As stated in our Code of Ethics, Pattonair strictly prohibits the use of slave labour and engagement in human trafficking. We require all suppliers to acknowledge and comply with our stance. Pattonair requires that our entire supply chain conduct business in a manner that respects human rights.

We are now implementing our own supplier due-diligence programme that includes specific survey questions related to slave labour and human trafficking. We will look to have engaged with our entire supply chain by the end of financial year 2017, and we will continue to drive compliance throughout our supply base.

If any supplier is unable to comply with supplier standards, including those regarding slavery and human trafficking, we will take appropriate action. This may include the cancellation of purchase orders as well as alerting local authorities of any suspected or confirmed illegal activity.

All Pattonair employees with direct responsibility for supply chain management will be trained on ethics and compliance.

Aims and objectives

Following a review of the effectiveness of the steps we have taken this year to ensure that there is no slavery or human trafficking in our supply chains we intend to take the following further steps to combat slavery and human trafficking:

Actions Deadline

Revised code of ethics published               October 2016

Awareness workshops with suppliers at our annual supplier conference November 2016

Supply chain mapping exercise for risk assessments         March 2017

Whistleblowing policy to be amended to include options for people external to Pattonair to raise concerns                October 2016

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (UK) and the Trafficking Victims Protection Act of 2000 (USA), and constitutes Pattonair’s slavery and human trafficking statement for the financial year ending 2016.


PATTONAIR COOKIE POLICY

INFORMATION ABOUT OUR USE OF COOKIES

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

READ FULL PATTONAIR COOKIE POLICY HERE


PATTONAIR GENDER PAY REPORT 2019

READ FULL PATTONAIR GENDER PAY REPORT HERE


PATTONAIR CODE OF CONDUCT

Our Business

Throughout our businesses across Europe, the Americas and Asia, Pattonair is committed to the highest standards of ethics and business conduct. We strive to provide a world class service to our worldwide customers by living out our core values: Build with Integrity, Fairness and Trust; Challenge and Innovate; Always Put Outstanding Service First and Make Ambition Work. In abiding by these values we aim to uphold our reputation for being reliable and acting with integrity, respecting the laws, regulations, traditions and cultures of the countries in which our customers, we and our suppliers operate. We pride ourselves on high standards of service and the professional and ethical conduct of all our employees who act on behalf of Pattonair and who are expected to treat compliance to this Code of Conduct as a key element of their daily working lives.

Similarly, our suppliers are responsible for ensuring that their directors, officers, employees, representatives and suppliers understand and comply with the expectation in this Code of Conduct. However, this Code of Conduct is not intended to be all inclusive and suppliers are obliged to ensure appropriate compliance to all applicable laws, regulations, traditions and cultures of the countries in which they and their suppliers operate.

This Code of Conduct applies to all customers, employees and suppliers and sets a minimum standard for expected behaviour and helps to sustain and enhance our joint reputation and contribute to Shareholder long-term value creation. We expect that Suppliers will support Pattonair with appropriate data and site access plus the provision of additional data, certificates etc. evidencing compliance and take prompt action to correct any non-compliance.

Legal Compliance and Business Ethics

General Compliance

Pattonair, its customers and suppliers are required to comply with all the laws and regulations of the countries in which they operate. As a minimum this includes compliance with laws prohibiting any form of corruption, bribery, sales or shipments to embargoed countries and the restriction of imports or exports where necessary, as well as any laws concerning the governance of business transactions.

Bribery and Corruption

Anything which constitutes or creates an unfair or improper business advantage should be avoided. This may even be something which appears to influence someone’s business judgement. Bribes may not be offered, promised, demanded, given or accepted in order to gain such an advantage including the provision of excessive or frequent gifts or entertainment.

Conflicts of Interest

Employees should recognise personal relationships and situations where it will be difficult to apply objectivity. All instances of an actual or apparent conflict of interest must be reported to Pattonair. This includes instances of where personal relationship can impact on a business decision or where an employee has an ownership or financial interest in Pattonair, a supplier or customer.

Legal and Fair Competition

Pattonair competes aggressively and fairly in its market sectors. We do not collude with our competitors on pricing matters, inventory levels, products, bids or sales agreements. We expect our supply chain to adhere to the same. Pattonair complies with all competition in business transactions and does not engage in any deceptive practices or espionage to get information on our competitors.

Government Procurement

All government requests or investigations received by Pattonair are fully cooperated with. This includes compliance with government legislation regarding fair competition, specification conformance, government accounting and pricing requirements. All government requests are responded to in an accurate and truthful manner.

Human Rights

Pattonair maintains the highest respect for the protection and enforcement of human rights. Pattonair, its customers, suppliers and employees are responsible for upholding these values. We do not accept discrimination of any kind and being compliant with modern slavery and human-trafficking law, we will not tolerate compulsory, forced or child labour. Pattonair and our trading partners must comply with all relevant child labour laws and should not employ anyone who is under the age of fifteen or, where it is higher, the mandatory school leaving age in that locality. All employees, stakeholders and suppliers are respected by all Pattonair staff.

International Trade

Pattonair complies with all UK, US and international laws and regulations in its global trade. This covers the export and import of goods and transfer of goods, technologies and services, including both civil and military applications. We accurately report our importing and exporting transactions, seeing Trade Compliance knowledge a fundamental aspect of our business strategy.

Quality

Pattonair focusses on quality to meet our customers’ diverse needs including delivering products and services on time, to the correct specification and at the agreed price. To do this we expect our suppliers to comply with all quality control requirements, both dictated by industry governing legislation and via specific customer requirements. Any issue regarding safety should be reported immediately.

Integrity

Integrity is the core value of Pattonair’s Code of Ethics. Pattonair is committed to conducting business fairly and honestly. All Pattonair employees are expected to act, at all times and in all circumstances, with the highest sense of integrity on behalf of the Company, acting in a manner that protects and enhances the Company’s corporate reputation. To this end:

Pattonair employees shall be ‘straightforward and honest in all professional and business relationships.’

No employee shall engage in personal activities or pursue financial or business interests which might give rise to, or give the appearance of, conflicts of interest with Pattonair, or which might compromise their ability to meet the responsibilities of their job.

Pattonair does not offer, promise, give, demand or accept bribes or other unethical advantage in order to obtain, retain or give business or other advantage.

Pattonair employees who have access to privileged information (including proprietary and confidential information, whether belonging to Pattonair or others) must not use it to achieve personal gain for themselves or others.

Pattonair employees must ensure proper and responsible use of all Pattonair’ assets, including physical property, intangible assets, IT equipment and communication resources.

Protection of Information & Assets

Trading partners and employees shall respect intellectual property rights and safeguard their own and third parties’ information, including the protection of IT assets from theft or misappropriation. Transfer of intellectual property, technology and know-how will be undertaken in a manner that protects intellectual property rights.

Monitoring and Record Keeping

Trading partners and employees shall have processes to identify, understand, and implement applicable laws including regulations and requirements of this code. All stakeholders shall maintain documents and records to ensure regulatory compliance, and compliance with this code, and will make these available to the relevant parties on request.

Workplace

Pattonair is built upon honesty, integrity and trust and we are committed to ensuring fair employment practices. This includes complying with legislation on all matters of employment including working time, wages, diversity, equality and prohibiting discrimination. Our statement on Modern Slavery is available to support this.

Our facilities are not only safe places to work with compliance to Health Safety and Environment practices but they encourage team working, innovation and flexibility. Compliance with laws is something we strive to exceed upon. Our no tolerance approach to intoxication at work is also supported by our wellbeing practices. It is expected that our suppliers operate to the same standards as ourselves and are able to demonstrate good HSE practices in all of their operations.

We work in diverse locations but operate within standard procedures for health and safety at work. We report annually on not only our results but our aims. Our Corporate Social Responsibility report is available to support this.

Pattonair and our supply chain, from time to time, may come into contact with conflict minerals. It is our expectation that we have controls in place to minimise this requirement and reliance. By focusing on alternative sources we aim to minimise this and our risk to the environment.

Health Safety and the Environment

Pattonair promotes environmental excellence across all facilities and expects the same throughout the supply chain in order to reduce our environmental footprint. We actively reduce the production of and encourage the recycling of waste; whilst also promoting car sharing and cycle to work schemes for our employees. This is communicated throughout the organisation in compliance with environmental legislation and ISO14001:2015.

Corporate Social Responsibility and Community

We operate in locations across the world yet wherever we are based we act with integrity as good corporate citizens. We focus on employee safety, bringing fairness and consistency in each region we operate in, and working with local communities to have a positive impact on the local area. Our Corporate Social Responsibility report is available to support this.

Applicability

The integrity of Pattonair ultimately depends upon the individual actions of our directors, officers, employees and representatives, all over the world. Each one is personally responsible and accountable for compliance with this Code.

Code Compliance

All entities are responsible for ensuring compliance to this Code of Conduct with their directors, officers, employees, representatives and suppliers and any suspected non-compliance or questions relating to expectations should be addressed to: codeofconduct@pattonair.com

All correspondence to the above will be treated confidentially and investigated properly and promptly whether it be raised internally or externally.

Pattonair operates an anti-retaliation policy. Actions cannot be taken against individuals for raising concerns in good faith.


PATTONAIR WHISTLE BLOWING

Aim and Purpose of the Policy

The aim of this Policy is to inform employees of the Companies commitment to the highest standards of openness, honesty and accountability. Where an individual discovers information which they believe shows serious malpractice, wrongdoing or neglect within the organisation then this information should be disclosed internally without fear of reprisal. Officially this is called 'making a disclosure in the public interest'.

General

The Company recognises that incidents of wrongdoing in the workplace are unacceptable and is therefore committed to ensuring that any such malpractice is prevented and immediately dealt with if it should arise.

Employees are often the first to realise that there may be something wrong within the Company, however, may not express concerns because of feelings that speaking up would be disloyal to colleagues or to the Company. Employees may also fear harassment or victimisation. In these circumstances it may be easier to ignore the concern rather than report what may be just a suspicion of malpractice.

The Company encourages its employees to raise genuine concerns about wrongdoing at the earliest practicable stage rather than wait for proof. Wrongdoing within the Company is taken very seriously.

This procedure is to provide safeguards to enable all employees to raise concerns about wrongdoing in connection with the Company. The aim is to provide a rapid mechanism under which genuine concerns made in good faith can be raised internally without fear of repercussions to the individual.

  • The Company believes that good communications among workers at all levels promote better business practice
  • The Company will not tolerate wrongdoing by workers at any level.
  • If you have a serious concern relating to one of the areas listed below the matter can be reported, in the manner set out in this procedure, without fear of reprisals.
  • The purpose of this procedure is to enable the Company to investigate and deal properly and sensitively with allegations of wrongdoing raised by employees.
  • You should use this procedure if you wish to report or raise concerns about wrongdoing of the nature listed below. It is not intended to replace the grievance procedure, which continues to be the appropriate way to raise personal issues relating to your job or employment.

Customers & Suppliers

If an employee genuinely believes that the Company or any employee of the Company has taken, is intending or has failed to take action that is reasonably believed, will lead or amount to:

  • A criminal offence;
  • A failure to comply with any legal obligations;
  • A miscarriage of justice;
  • Danger to the health and safety of any individual;
  • Damage to the environment; or
  • the deliberate concealment of information tending to show any of the matters listed above.

Employees should disclose this information in confidence through our externally provided confidential reporting service; Safecall (details on page 5), a multilanguage, externally managed reporting service. If such a disclosure is made, full details should be provided and, where possible, supporting evidence. It is important that these types of issues are dealt with sensitively and quickly. Anonymous disclosures are allowed but are h2ly discouraged as they are likely to hinder effective investigation. If you disclose information in accordance with this procedure, in so far as it is reasonably practicable, your identity will be kept confidential.

Following receipt of an investigation report from Safecall:

  1. The Company will promptly investigate any allegation and will take whatever action it considers appropriate. Assistance may be required during the investigation from the employee making the allegation, where assistance is required it will be done so sensitively and confidentially. The allegation will be addressed seriously and the employee making the allegation will be informed of the outcome of the investigation as soon as practicable.
  2. If it is reasonably believed by the employee making the complaint that the nature of the concern relates to any of the areas set out above and the information is disclosed to the appropriate person under this procedure in good faith, no action will be taken against the employee for making the disclosure.
  3. The Company will take appropriate action against any person:
  • Found to be victimising another person for using this procedure, or deterring any person from reporting genuine concerns under it; or
  • Making the disclosure/allegation maliciously, or where there were no reasonable grounds for believing that the information supplied was accurate.
  • For those people employed directly by the Company, disciplinary action may be taken, which may result in dismissal.

PATTONAIR PRIVACY POLICY

PRIVACY POLICY – VERSION FEBRUARY 2019

Pattonair Limited and Pattonair (Derby) Limited (“we”) are committed to protecting and respecting your privacy. This policy (together with our website terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. For the purpose of the General Data Protection Regulation (the “GDPR”), the data controller is Pattonair Limited of Ascot Business Park 50 Longbridge Lane Derby DE24 8UJ.

INFORMATION WE MAY COLLECT FROM YOU

Information that you provide by filling in forms on www.pattonair.com (our “Site”). This includes information provided at the time of registering to log-in to our customer or supplier portals (“Portals”), posting material or requesting further services. We may also ask you for information if you report a problem with our Site. If you contact us, we may keep a record of that correspondence. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them. We may also retain:

  • details of transactions (if any) you carry out through our Site and of the fulfilment of your orders; and
  • details of your visits to our Site including traffic data, location data, weblogs and other communication data, the uses for which will be explained further below.

TECHNICAL DATA

We may collect information about the device you use to browse our Site, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

COOKIES

A cookie is a small file of letters and numbers that we store on your browser or device if you agree.

We use the following types of cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into our Portals, or help the Site to remember what language or region you have chosen to display.
  • Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors and to see how visitors move around our Site. This helps us to improve the way the Site works, for example, by ensuring that users are finding what they are looking for easily.
  • Social Media Sharing Buttons. We do use sharing buttons in order to make it easier for you to follow our content via your social media pages. These buttons are third-party cookies which are placed onto your device when you visit our Site. Even without you clicking on the relevant sharing button, these sites are aware that you have visited our Site, and may use this information when building their profile of you, and deciding what advertisements you might like to see. You should check the respective policies of each of these social networks to see how exactly they use your personal data. This process does not involve us collecting or storing any of your personal data ourselves.

You can refuse to accept all or some cookies by modifying settings within your browser (for guidance on how to do this visit www.aboutcookies.org). However, if you block strictly necessary cookies, you may be unable to access certain parts of our Site.

WHERE WE STORE YOUR PERSONAL DATA

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us, our parent company or for one of our suppliers. Since Pattonair is a global company, we often need to transfer personal data about our clients to other Pattonair branches located in different jurisdictions, including the United States. Where this happens, your personal data is protected by means of a data sharing agreement which we have put in place between the various Pattonair companies who have access to it.

We will take all steps reasonably necessary to ensure that your data is treated in accordance with this privacy policy and the GDPR. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data once it reaches us, we cannot guarantee the security of your data transmitted to our site. Any transmission is at your own risk. Once we have received your personal data, we will employ a variety of physical and technical measures to keep it safe and prevent unauthorised access to, use or disclosure of it. We control who has access to your data (using both physical and electronic means). These means include an electronic firewall and other protection measures that involve virus-scanning, installation of security patches, vulnerability testing, backup and recovery planning and other steps designed to improve data protection. Our staff receive data protection training and we have a set of detailed procedures, which they are required to follow when handling personal data.

USES MADE OF YOUR PERSONAL DATA

We will only use your personal data where the law allows us to do so. Most commonly, we will use it:

  • with your consent (note that you may withdraw this at any time, though any use of your personal data made before you withdraw consent will still be lawful);
  • where we need to perform a contract with you directly;
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (see the Legitimate Interests section below); or
  • where we need to comply with a legal or regulatory obligation.

We use information held about you in the following ways:

  • To ensure that content from our site is presented in the most effective manner for you and for your device;
  • To provide you with information, products or services that you request from us;
  • To carry out our obligations arising from any contracts entered into between you and us, or between us and your employer;
  • To notify you about changes to our Site or the services we offer.

LEGITIMATE INTERESTS

We may rely on legitimate interests to process your personal data, provided that your interests do not override our own.

Where we rely on legitimate interests, these interests are:

  • to keep our records updated and to study how our Site and other services are used;
  • to administer and protect our business and web presence (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting);
  • to inform our marketing strategies; and
  • to grow our business, including by providing you with information about our goods and services that may be of interest to you.

DISCLOSURE OF YOUR DATA

We may disclose your personal data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. We may disclose your personal data to third parties:

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  • If Pattonair Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Pattonair Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We may also share your personal data with credit reference agencies (CRAs) for the purpose of credit risk assessment and they will give us information about you, such as about your financial history. We do this to assess creditworthiness, check your identity, manage your account, trace and recover debts and prevent criminal activity. We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at http://www.experian.co.uk/crain/index.html.

OTHER SITES

Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.

RETAINING YOUR PERSONAL DATA

We collect and store personal data for purposes connected with our business. As such, we will only retain your personal data for as long as necessary for those purposes. We verify our records periodically and if we learn that you are no longer involved with a business that is in our database, we will erase your personal data.

We keep information which forms part of our business record for a minimum of seven years. That is because we may need it in some way to support a claim or defence in court. That is also the period within which our tax collecting authorities may demand to know it. We may retain certain records for longer than seven years in a few specific cases where required by law.

YOUR RIGHTS

You have the right to ask us not to process your personal data for marketing purposes, we will inform you if we intend to use your data for such purposes or if we intend to disclose it to any third party for such purposes. You can also exercise the right at any time by contacting us at our Data Protection Department, Pattonair Limited, Ascot Business Park, Longbridge Lane, Derby DE24 8UJ.

ACCESS TO INFORMATION

You have the right to access any part of the personal data that Pattonair holds about you. Your right of access can be exercised in accordance with data protection law. Any access request will be processed and completed within 1 month of the request being made.

RIGHT TO ERASURE

You have the right to request the deletion or removal of personal data in circumstances where there is no compelling reason for us to continue to hold or process it.

RIGHT TO DATA PORTABILITY

You have the right to obtain and re-use your personal data for your own purposes across different services. Your right to data portability can be exercised in accordance with the GDPR. Any request will be processed without undue delay, and the data will be provided in a structured and readable form.

Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so (for example, because the data no longer exists or there is an exception which applies to your request).

MAKING A COMPLAINT

If you believe that your data protection or privacy rights have been infringed, you should contact the UK Information Commissioner's Office, which oversees data protection compliance in the UK. Details of how to do this can be found at www.ico.org.uk.

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

CONTACT

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Data Protection Department, Pattonair Limited, Ascot Business Park, Longbridge Lane, Derby, DE24 8UJ. You can also e-mail us at gdpr@pattonair.com or call us on 01332 886 200 and ask to speak to the Chief Information Officer.


PATTONAIR TERMS AND CONDITIONS

This page (together with the documents referred to on it) tells you the terms of use on which you may make use of our website www.pattonair.com (our site), whether as a guest or a registered user. Please read these terms of use carefully before you start to use the site. By using our site, you indicate that you accept these terms of use and that you agree to abide by them. If you do not agree to these terms of use, please refrain from using our site.

INFORMATION ABOUT US

www.pattonair.com is a site operated by Pattonair Limited ('We'). We are registered in England and Wales under company number 00974964 and have our registered office at Ascot Business Park 50 Longbridge Lane Derby DE24 8UJ ('Longbridge Lane'). Our main trading address is also at Longbridge Lane. Our VAT number is [108308632]. We are a limited company.

ACCESSING OUR SITE

Access to our site is permitted on a temporary basis, and we reserve the right to withdraw or amend the service we provide on our site without notice (see below). We will not be liable if for any reason our site is unavailable at any time or for any period. From time to time, we may restrict access to some parts of our site, or our entire site, to users who have registered with us. If you choose, or you are provided with, a user identification code, password or any other piece of information as part of our security procedures, you must treat such information as confidential, and you must not disclose it to any third party. We have the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if in our opinion you have failed to comply with any of the provisions of these terms of use. You are responsible for making all arrangements necessary for you to have access to our site. You are also responsible for ensuring that all persons who access our site through your internet connection are aware of these terms, and that they comply with them.

INTELLECTUAL PROPERTY RIGHTS

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

RELIANCE ON INFORMATION POSTED

Commentary and other materials on our site are not intended to amount to advice on which reliance should be placed. We therefore disclaim all liability and responsibility arising from any reliance placed on such materials by any visitor to our site, or by anyone who may be informed of any of its contents. In particular we make no representation that any information on our site is suitable or available for use outside the United Kingdom and no action should be taken or not taken on reliance upon information within linked to or from this site.

OUR SITE CHANGES REGULARLY

We aim to update our site regularly, and may change the content at any time. If the need arises, we may suspend access to our site, or close it indefinitely. Any of the material on our site may be out of date at any given time, and we are under no obligation to update such material.

OUR LIABILITY

The material displayed on our site is provided without any guarantees, conditions or warranties as to its accuracy. To the extent permitted by law, we, other members of our group of companies and third parties connected to us hereby expressly exclude:

All conditions, warranties and other terms which might otherwise be implied by statute, common law or the law of equity.

Any liability for any direct, indirect or consequential loss or damage incurred by any user in connection with our site or in connection with the use, inability to use, or results of the use of our site, any websites linked to it and any materials posted on it, including, without limitation any liability for:

  • loss of income or revenue;
  • loss of business;
  • loss of profits or contracts;
  • loss of anticipated savings;
  • loss of data;
  • loss of goodwill;
  • wasted management or office time;
  • Any other loss or damage of any kind, however arising and whether caused by tort (including negligence), breach of contract or otherwise, even if foreseeable, provided that this condition shall not prevent claims for loss of or damage to your tangible property or any other claims for direct financial loss that are not excluded by any of the categories set out above. This does not affect our liability for death or personal injury arising from our negligence, nor our liability for fraudulent misrepresentation or misrepresentation as to a fundamental matter, nor any other liability which cannot be excluded or limited under applicable law.

INFORMATION ABOUT YOU AND YOUR VISITS TO OUR SITE

We process information about you in accordance with our privacy policy which is also contained on this site. By using our site, you consent to such processing and you warrant that all data provided by you is accurate.

TRANSACTIONS CONCLUDED THROUGH OUR SITE

Contracts for the supply of goods services or information formed through our site or as a result of visits made by you are governed by our terms and conditions of supply.

VIRUSES, HACKING AND OTHER OFFENCES

You must not misuse our site by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our site. You must not attack our site via a denial-of-service attack or a distributed denial-of service attack. By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately. We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our site or to your downloading of any material posted on it, or on any website linked to it.

LINKING TO OUR SITE

If you have obtained our prior consent in writing you may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it, but you must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists. You must not establish a link from any website that is not owned by you. Our site must not be framed on any other site, nor may you create a link to any part of our site other than the home page. We reserve the right to withdraw linking permission without notice.

LINKS FROM OUR SITE

Where our site contains links to other sites and resources provided by third parties, these links are provided for your information only. We have no control over the contents of those sites or resources, and accept no responsibility for them or for any loss or damage that may arise from your use of them.

JURISDICTION AND APPLICABLE LAW

The English courts will have exclusive jurisdiction over any claim arising from, or related to, a visit to our site although we retain the right to bring proceedings against you for breach of these conditions in your country of residence or any other relevant country. These terms of use and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the law of England and Wales.

VARIATIONS

We may revise these terms of use at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we made, as they are binding on you. Some of the provisions contained in these terms of use may also be superseded by provisions or notices published elsewhere on our site. Thank you for visiting our site.

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