Policies
Corporate Policies


CERATECH ACCURATUS LTD COMPLAINTS HANDLING POLICY

1. Definitions
1.1 In this Complaints Policy the following expressions have the following meanings:
“Appeal” means your request to escalate a Complaint from Level One to Level Two if you are not satisfied with the outcome at Level One;
“Appeal Handler” means an employee of Ceratech Accuratus Limited who will handle Level Two Complaints;
“Business Day” means, any day other than Saturday, Sunday or any bank holiday
“Complaint” Means a complaint about goods and/or services sold by Ceratech Accuratus Limited, about our customer service, or about our employees, agents or subcontractors.
“Complaint Handler” Means any employee of Ceratech Accuratus Limited.
“Complaints Policy” means this document;
“Complaints Procedure” means the internal complaints handling procedure of Ceratech Accuratus Ltd which is followed when handling a Complaint;
“Complaint Reference” means a unique code assigned to your Complaint that will be used to track your Complaint;
“Level One” means the first stage in our complaints handling procedure under which your Complaint will be handled by a Complaint Handler; and
“Level Two” Means the second stage in our complaints handling procedure under which you may appeal the outcome of a Level One Complaint. Your Complaint will be handled by an Appeal Handler.

2. Purpose of this Complaints Policy
2.1 Ceratech Accuratus Ltd welcomes and encourages feedback of all kinds from our customers. If you have a Complaint about our goods, and/or services, our customer service, or about our employees, agents or subcontractors, not only do we want to resolve it to your satisfaction but we also want to learn from it in order to improve our business and customer experience in the future.

2.2 It is our policy to resolve Complaints quickly and fairly, where possible without recourse to formal investigations or external bodies. In particular, the aims of this Complaints Policy are:

2.2.1 To provide a clear and fair procedure for any customers who wish to make a Complaint about Ceratech Accuratus Ltd, our goods, and/or services, our customer service, or about our employees, agents or subcontractors;

2.2.2 To ensure that everyone working for or with Ceratech Accuratus Ltd knows how to handle Complaints made by our customers;

2.2.3 To ensure that all Complaints are handled equally and in a fair and timely fashion;

2.2.4 To ensure that important information is gathered from Complaints and used in the future to avoid such a situation arising again.

3. What this Complaints Policy Covers
3.1 This Complaints Policy applies to the sale of goods and/or the provision of services by Ceratech Accuratus Ltd to our customer service and to our employees, agents or subcontractors.

3.2 For the purposes of this Complaints Policy, any reference to Ceratech Accuratus Ltd also includes our employees, agent or subcontractors.

3.3 Complaints may relate to any of our activities and may include (but not be limited to):

3.3.1 The quality of customer service you have received from us;

3.3.2 The behaviour and/or professional competence of our employees, agents or subcontractors;

3.3.3 Delays, defects or other problems associated with the sale of goods by us:

3.3.4 Delays, defects, poor workmanship or other problems associated with the provision of services by us.

3.4 The following are not considered to be Complaints and should therefore be directed to the appropriate person or department:

3.4.1 General questions about our goods and/or services;

3.4.2 Returns of damaged, faulty, incorrect or unwanted goods for exchange or refund in accordance with our terms of trade where there is no further complaint;

3.4.3 Matters concerning contractual or other legal disputes;

3.4.4 Formal requests for the disclosure of information, for example, under the Data Protection Act;

4. Making a Complaint
4.1 All Complaints, whether they concern our goods and/or services, our customer service, or our employees, agents or subcontractors, should be made in one of the following ways:

4.1.1 In writing, addressed to Ceratech Accuratus Ltd at Ceratech House, Unit 3 Grove Park, Alton. Hants, GU34 2QG, or emailed to sales@ceratech.co.uk

4.1.2 Using our Complaints Form, following the instructions included with the form;

4.1.3 By contacting us by telephone on 01420 85470.

4.2 When making a Complaint, you will be required to provide the following information in as much detail as is reasonably possible:

4.2.1 Your name, address, telephone number and email address (We will contact you using your preferred contact method as your Complaint is handled);

4.2.2 If you are making a Complaint on behalf of someone else, that person’s name and contact details as well as your own;

4.2.3 If you are making a Complaint about a particular transaction, the invoice or delivery note number.

4.2.4 If you are making a Complaint about a particular employee agent or subcontractor of ours, the name and, where appropriate, position of that employee, agent or subcontractor:

4.2.5 Further details of your Complaint including, as appropriate, all times, dates, events, and people involved;

4.2.6 Details of any documents or other evidence you wish to rely on in support of your Complaint;

4.2.7 Details of what you would like us to do to resolve your Complaint and to put things right. (Please note that whilst we will make every reasonable effort to accommodate such requests, we are not bound to take any action beyond that which we may be contractually or otherwise legally obliged to take.)

5. How We Handle Your Complaint
5.1 Ceratech Accuratus Limited operates a two-stage complaints handling procedure. Following our Complaints Procedure, our aim is to always resolve Complaints to your satisfaction at Level One without further recourse to Level Two. If you are not satisfied at the end of Level One, you may escalate your Complaint to Level Two.

5.2 Level One:

5.2.1 Upon receipt of your Complaint, the complaint will be logged in our complaints log and we will acknowledge receipt of it in writing within seven working days giving you a Complaint Reference.

5.2.2 When we acknowledge receipt of your Complaint we will also provide details of your Complaint Handler. This may be the person to whom your original Complaint was directed (as above) or your Complaint may be assigned to another appropriate member of our team.

5.2.3 If your Complaint relates to a specific employee, agent or subcontractor, that person will be informed of your Complaint and given a fair and reasonable opportunity to respond. Any communication between you and the employee, agent or subcontractor in question should take place only via the Complaint Handler and we respectfully ask that you do not contact the employee, agent or subcontractor in question directly concerning the Complaint while we are working to resolve it.

5.2.4 If we require any further information or evidence from you, the Complaint Handler will contact you as quickly as is reasonably possible to ask for it. We ask that you use reasonable efforts to supply any such information or evidence quickly in order to avoid delaying the complaints handling process. If you are for any reason unable to provide such information or evidence we will use all reasonable efforts to proceed without it, however please be aware that we will not ask for further information or evidence unless we consider it important to the successful resolution of your Complaint.

5.2.5 We aim to resolve Level One Complaints within seven working days, however in some cases, particularly if your Complaint is of a complex nature, this may not be possible. If this is not possible for any reason you will be informed of the delay, the likely length of the delay and the reasons for it.

5.2.6 At the conclusion of the Level One complaints procedure, regardless of the outcome, we will provide you with full details of our investigation, our conclusions from that investigation, and any action taken as a result. You will also be reminded of your right to appeal our decision and escalate the complaint to Level Two in the form of an Appeal.

5.3 Level Two:

5.3.1 If you are not satisfied with the resolution of your complaint at Level One, you may appeal the decision within 14 working days, and have the complaint escalated to Level Two. Appeals are handled by the Directors of our team.

5.3.2 Appeals, quoting your original Complaint Reference, should be directed to your original Complaint Handler who will forward the request to an appropriate Appeal Handler. Receipt of Appeals will be acknowledged in writing within 14 working days. When we acknowledge receipt of your Appeal we will also provide details of your Appeal Handler.

5.3.3 If your Complaint relates to a specific employee, agent or subcontractor that person will be informed of your Appeal and given a further opportunity to respond. Any communication between you and the employee, agent or subcontractor in question should take place only via the Appeal Handler and we respectfully ask that you do not contact the employee, agent or subcontractor in question directly concerning the Complaint while we are working to resolve it.

5.3.4 If we require any further information or evidence from you, the Appeal Handler will contact you as quickly as is reasonably possible to ask for it. We ask that you use reasonable efforts to supply any such information or evidence to us quickly in order to avoid delaying the complaints handling process. If you are for any reason unable to provide such information or evidence we will use all reasonable efforts to proceed without it, however please be aware that we will not ask for further information or evidence unless we consider it important to the successful resolution of your Complaint.

5.3.5 We aim to resolve Level Two Complaints within 21 working days however in some cases, particularly if your Complaint is of a complex nature, this may not be possible. If this is not possible for any reason you will be informed of the delay, the likely length of the delay and the reasons for it.

5.3.6 At the conclusion of the Level Two procedure, regardless of the outcome, we will provide you with full details of our investigation, our conclusions from that investigation, and any action taken as a result. Our decision at this stage is final, subject to your right to seek External Resolution of your Complaint.

6. Confidentiality and Data Protection
6.1 All Complaints and information relating thereto are treated with the utmost confidence. Such information will only be shared with those employees, agents or subcontractors of Ceratech Accuratus Ltd who need to know in order to handle your Complaint.

6.2 All personal information that we may collect (including, but not limited to, your name and address) will be collected, used and held in accordance with the provisions of the Data Protection Act 1998 and your rights under that Act.

7. Questions and Further Information
If you have any questions or require further information about any aspect of this Complaints Policy or about our Complaints Procedure, please contact us by post, email or telephone.

8. Policy Responsibility and Review
8.1 Overall responsibility for this Complaints Policy within Ceratech Accuratus Ltd and the implementation thereof lies with Jacqueline Hodge.

8.2 This Complaints Policy is regularly reviewed and updated as required.

8.3 This Complaints Policy was adopted on 1st July 2014.

8.4 This Complaints Policy was last reviewed on 2nd February 2016.



CERATECH ACCURATUS LTD CORPORATE SOCIAL RESPONSIBILITY
All of Ceratech’s business activities are conducted based on principles adopted by the company. The main principle is to promote CSR (Corporate Social Responsibility) activities aimed at enhancing corporate values and contributions to global and local societies by communication.

Education regarding CSR and the code of conduct is provided to all employees.

HUMAN RIGHTS AND LABOUR
Ceratech Accuratus Limited is committed to achieving a working environment which provides equality of opportunity and freedom from unlawful discrimination on the grounds of race, sex, pregnancy and maternity, marital or civil partnership status, gender reassignment, disability, religion or beliefs, age or sexual orientation. They aim to remove unfair and discriminatory practices within the Company and to encourage full contribution from its diverse community. The Company is committed to actively opposing all forms of discrimination.

The Company also aims to provide a service that does not discriminate against its clients and customers in the means by which they can access the services and goods supplied by the Company. The Company believes that all employees and clients are entitled to be treated with respect and dignity.

Employees are employed on a voluntary basis and not engage in forced labour.

Ceratech respect human rights of employees and prohibit harsh and inhumane treatment such as maltreatment and/or various forms of harassment. Ceratech prohibit illegal discrimination during the process of job recruiting and hiring and endeavour to offer equal opportunity and fairness of treatment, prohibiting the use of child labour.

Ceratech pay the legal minimum wage or more and do not practice unfair wage deduction as a means of a disciplinary action.

Ceratech regulates working hours, holidays and offers flexible working hours.

The rights to freedom of all employees are respected, together with their security, in their lives.

The implementation of human rights and labour is regulated by Ceratech’s Equal Opportunity and Diversity Policy. There is a designated officer appointed and all employees are trained and educated on the policy.

All employees, subcontractors and agents of the Company are required to act in a way that does not subject any other employees or clients to direct or indirect discrimination, harassment or victimisation on the grounds of their race, sex, pregnancy or maternity, marital or civil partnership status, gender reassignment, disability, religion or beliefs, age or sexual orientation.

The co-operation of all employees is essential for the success of this Policy. Senior employees are expected to follow this Policy and to try to ensure that all employees, subcontractors and agents do the same.

Employees may be held independently and individually liable for their discriminatory acts by the Company and in some circumstances an Employment Tribunal may order them to pay compensation to the person who has suffered as a result of discriminatory acts.

The Company takes responsibility for achieving the objectives of this Policy, and endeavours to ensure compliance with relevant Legislation and Codes of Practice.

OCCUPATIONAL HEALTH AND SAFETY
Ceratech recognises and accepts its responsibilities under the Health and Safety at Work etc Act 1974 including the responsibility to:

Provide, promote and maintain a safe, hygienic and healthy place of work
Provide adequate information, instruction, training and supervision
Provide and maintain plant and equipment and safe systems of work
Provide appropriate safety regulations regarding equipment and instruments used in the company
Ensure safe access to and from the places of work to prevent accidents and work related ill health, whilst limiting physically demanding work
Provide appropriate controls concerning occupational injuries in the workplace
Properly manage accidents.

Ceratech has procedures in place for all of the above.

There is a designated officer appointed and all employees are trained and educated on the policy.
Risk assessments are regularly carried out. Fire and lighting services are regularly maintained and serviced. Personnel are trained and educated on all aspects including first aid.

PRODUCT QUALITY AND SAFETY/INFORMATION SECURITY
Ceratech maintains and promotes information security in order to properly protect their own information and information systems of third parties and are registered for data protection.

They maintain high standards of safety and quality in their products and services.

They have an established quality management system which includes organisational structure, planning activities, responsibilities, procedures and resources to promote quality assurance.

The system is regulated by rules and manuals. Regular audits and internal investigations take place along with training and education to employees and regulations of this training. Designated managers are appointed.

FAIR TRADING
Ceratech does not tolerate corruption in any form including bribery and extortion nor does it allow anyone acting on our behalf to engage in such conduct. This is for all employees across the whole of the company.

Ceratech prohibits the offering and receiving of inappropriate benefits to and from stakeholders including gifts, awards, money, entertaining beyond what is reasonable lawful and customary in the applicable country.

Patents, trademarks, copyrights and trade secrets are respected and the usage of a third party’s intellectual property without permission may constitute an infringement of intellectual property rights unless otherwise permitted by law.

Ceratech aims to provide and disclose appropriate company information, use appropriate procedures and ensure the information on products and services is correct and accurate. Agreements or practices that restrict free trading and competition are prohibited.

SUPPLY CHAIN MANAGEMENT
Ceratech want to ensure that chosen suppliers share the same principles and values. High standards are expected from any vendor wishing to do business with them.

All of their policies are clearly established and are available to our Suppliers.
Suppliers for up to date information regarding their policies, procedures and compliance to the WEEE, ROHS and other directives.

ENVIRONMENT
The Environmental Policy of Ceratech is to ensure, so far as it is reasonably practical, that its operations will be carried out with a commitment to protecting and enhancing the environment.

As an office high levels of waste paper products are generated. However as Ceratech strive for excellence in every aspect of the business they are committed to minimising the environmental impacts on the business operation.

The aims are to:
Continuously improve environmental performance particularly with regards to recycling and re-use of paper.
Where possible to use recycled or ecologically friendly paper.

To use ‘waste’ paper for notepads unless confidentiality may be compromised.

Reduce consumption of resources and improve the efficiency of those resources by printing double sided where practicable

Manage waste generated from business operations according to the principles of reduction, re-use and recycling

Recycle all paper products, ink or toner cartridges.

Comply as a minimum with all relevant environmental legislation as well as other environmental requirements.

Designated Managers are appointed and regular audits take place to ensure compliance in all levels.

CONFLICT MINERALS ISSUE
Conflict minerals – those mined from the Democratic Republic of Congo and other conflict zones where various militias control precious natural resources and abuse human rights – have been a growing area of concern to both Ceratech and the public. Ceratech are committed to providing customers with products that are responsibly manufactured and verified as free of conflict minerals.

Ceratech requires suppliers to evaluate the origin or source of their materials to verify that they have not been mined from a conflict zone. If conflict minerals are found in their materials, the supplier must disclose this and take steps to develop and implement controls to avoid these minerals in the future.

Ceratech expect their suppliers to have in place policies and due diligence measures that will enable them to reasonably assure that products and components supplied to them containing conflict minerals are DRC conflict free.

In support of this Ceratech will:

• Exercise due diligence with relevant suppliers
• Provide, and expect suppliers to cooperate in providing, due diligence information to confirm the tantalum, tin, tungsten, and gold in the supply-chain are “conflict free”
• Collaborate with suppliers to enable products that are DRC conflict free.
• Commit to transparency in the implementation of this policy

Competition Law
We will take all necessary steps to ensure that we are fully compliant with applicable competition and anti-trust laws. It is against the law for us to agree with you what price we will sell any product at or have any agreement or arrangement that puts a floor on the price that the goods are sold.

The same also applies to our customers: it is against the law for us to tell them what price we can sell products at or to require or incentivise them to keep their prices above a certain level.

Intellectual Property

We will not sell any product that deliberately or clearly infringes the intellectual property rights of any third party.

Confidential Information

Neither us nor our customers should share confidential information inappropriately or use confidential information that we should not have.

We will always provide advice and support in relation to the sale of our products. We will not share with you any confidential information which we may have about our other customers or competitors. We expect all of our customers to act in an equivalent way in relation to disclosing confidential information about our competitors or us.


Environmental Policy
JUNE 2016

The Environmental Policy of Ceratech Accuratus Limited (“the Company”) is to ensure so far as it is reasonably practicable that its operations will be carried out with a commitment to protecting and enhancing the environment.

Ceratech endeavour to comply with all laws and regulations that support the protection of the environment. These laws and regulations cover standards, packaging reductions and battery compliance.

As an office we know that we generate waste paper products. However as we strive for excellence in every aspect of our business we are committed to minimising the environmental impacts of the business operation.

1. Our stated aims are to:
1.1 Aim to continuously improve our environmental performance particularly with regards to our recycling and re-use of paper.
1.2 Where possible we will use recycled or ecologically friendly paper.
1.3 We will use ‘waste’ paper for notepads unless confidentiality may be compromised.
1.4 Reduce our consumption of resources and improve the efficiency of those resources by printing double sided where practicable
1.5 Manage waste generated from my business operations according to the principles of reduction, re-use and recycling
1.6 Recycle all paper products, ink or toner cartridges.
1.7 Comply as a minimum with ail relevant environmental legislation as well as other environmental requirements.

This Environmental Policy Statement will be regularly reviewed and updated as necessary. The management team endorses these policy statements and is fully committed to their implementation.

This Environmental Policy Statement has been approved & authorised by: Name: ANGELA LENNOX

Position: SALES DIRECTOR

Date: June 2016


Equal Opportunities and Diversity Policy
June 2016

1. Policy Statement
Ceratech Accuratus Limited (“the Company”) is committed to achieving a working environment which provides equality of opportunity and freedom from unlawful discrimination on the grounds of race, sex, pregnancy and maternity, marital or civil partnership status, gender reassignment, disability, religion or beliefs, age or sexual orientation. This Policy aims to remove unfair and discriminatory practices within the Company and to encourage full contribution from its diverse community. The Company is committed to actively opposing all forms of discrimination.

The Company also aims to provide a service that does not discriminate against its clients and customers in the means by which they can access the services and goods supplied by the Company. The Company believes that all employees and clients are entitled to be treated with respect and dignity.

2. Objectives of this Policy
2.1 To prevent, reduce and stop all forms of unlawful discrimination in line with the Equality Act 2010.

2.2 To ensure that recruitment, promotion, training, development, assessment, benefits, pay, terms and conditions of employment, redundancy and dismissals are determined on the basis of capability, qualifications, experience, skills and productivity.

Definition of Discrimination
Discrimination is unequal or differential treatment which leads to one person being treated more or less favourably than others are, or would be, treated in the same or similar circumstances on the grounds of race, sex, pregnancy and maternity, marital or civil partnership status, gender reassignment, disability, religion or beliefs, age or sexual orientation. Discrimination may be direct or indirect, and includes discrimination by perception and association.

4. Types of Discrimination
4.1 Direct Discrimination
This occurs when a person or a policy intentionally treats a person less favourably than another on the grounds of race, sex, pregnancy and maternity, marital or civil partnership status, gender reassignment, disability, religion or beliefs, age or sexual orientation.

4.2 Indirect Discrimination
This is the application of a policy, criterion or practice which the employer applies to all employees but which is such that:
. It is it detrimental to a considerably larger proportion of people from the group that the person the employer is applying it to represents;
. The employer cannot justify the need for the application of the policy on a neutral basis; and
. The person to whom the employer is applying it suffers detriment from the application of the policy.
Example: A requirement that all employees must be 6ft tall if that requirement is not justified by the position would indirectly discriminate against employees with an oriental ethnic origin, as they are less likely to be able to fulfil this requirement.

4.3 Harassment
This occurs when a person is subjected to unwanted conduct that has the purpose or effect of violating their dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment. 

5 Victimisation
This occurs when a person is treated less favourably because they have bought or intend to bring proceedings or they have given or intend to give evidence.

6. Unlawful Reasons for Discrimination
6.1 Sex
It is not permissible to treat a person less favourably on the grounds of sex, marital status, civil partnership, pregnancy or maternity, gender reassignment or transgender status. This applies to men, women and those undergoing or intending to undergo gender reassignment. Sexual harassment of men and women can be found to constitute sex discrimination.
Example: Asking a woman during an interview if she is planning to have any (more) children constitutes discrimination on the ground of gender.

6.2 Age
It is not permissible to treat a person less favourably because of their age. This applies to people of all ages. This does not currently apply to the calculation of redundancy payments.

6.3 Disability
It is not permissible to treat a disabled person less favourably than a non-disabled person. Reasonable adjustments must be made to give the disabled person as much access to any sen/ices and ability to be employed, trained, or promoted as a non-disabled person.

6.4 Race
It is not permissible to treat a person less favourably because of their race, the colour of their skin, their nationality or their ethnic origin.

6.5 Sexual Orientation
It is not permissible to treat a person less favourably because of their sexual orientation. For example, an employer cannot refuse to employ a person because s/he is homosexual, heterosexual or bisexual.

6.6 Religion or Belief
It is not permissible to treat a person less favourably because of their religious beliefs or their religion or their lack of any religion or belief. 

7 Positive Action so Recruitment
Under the Equality Act 2010, positive action in recruitment and promotion applies as of 6 April 2011. ‘Positive action’ means the steps that the Company can take to encourage people from groups with different needs or with a past record of disadvantage or low participation, to apply for positions within the Company.
If the Company chooses to utilise positive action in recruitment, this will not be used to treat people with a protected characteristic more favourably, it will be used only in tie-break situations, when there are two candidates of equal merit applying for the same position.

8. Reasonable Adjustments
The Company has a duty to make reasonable adjustments to facilitate the employment of a disabled person. These may include:

8.1 Making adjustments to premises;

8.2 Re-allocating some or all of a disabled employee’s duties;

8.3 Transferring a disabled employee to a role better suited to their disability;

8.4 Relocating a disabled employee to a more suitable office;

8.5 Giving a disabled employee time off work for medical treatment or rehabilitation;

8.6 Providing training or mentoring for a disabled employee;

8.7 Supplying or modifying equipment, instruction and training manuals for disabled employees; or

8.8 Any other adjustments that the Company considers reasonable and necessary provided such adjustments are within the financial means of the Company.
If an employee has a disability and feels that any such adjustments could be made by the Company, they should contact the Designated Officer.

9. Responsibility for the Implementation of this Policy
All employees, subcontractors and agents of the Company are required to act in a way that does not subject any other employees or clients to direct or indirect discrimination, harassment or victimisation on the grounds of their race, sex, pregnancy or maternity, marital or civil partnership status, gender reassignment, disability, religion or beliefs, age or
sexual orientation.

The co-operation of all employees is essential for the success of this Policy. Senior employees are expected to follow this Policy and to try to ensure that all employees, subcontractors and agents do the same.
Employees may be held independently and individually liable for their discriminatory acts by the Company and in some circumstances an Employment Tribunal may order them to pay compensation to the person who has suffered as a result of discriminatory acts.
The Company takes responsibility for achieving the objectives of this Policy, and endeavours to ensure compliance with relevant Legislation and Codes of Practice.

10. Acting on Discriminatory Behaviour
in the event that an employee is the subject or perpetrator of, or witness to, discriminatory behaviour, please refer to the Ceratech’s grievance procedure.

11. Advice and Support on Discrimination
Employees may contact their employee or trade union representative if access to such an individual is possible.

Other contacts include:
Equality and Human Rights Commission
Arndale House
The Arndaie Centre
Manchester
M4 3AQ

3 More London Riverside Tooley Street London SE12RG
3rd Floor, 3 Callaghan Square
Cardiff
CF10 5BT

The Optima Building 58 Robertson Street Glasgow G2 8DU
Telephone (England): 0845 304 6610 Telephone (Waies): 0845 604 8810 Telephone (Scotland): 0845 604 5510
Website: www.equalityhumanrights.com

Citizens Advice Bureau Myddleton House 115-123 Pentonvilie Road London N1 9LZ
Website: www.citizensadvice.org.uk

Community Legal Services Direct
Telephone: 0845 345 4 345 Website: www.dsdirect.org.uk

12. Extent of the Policy

12.1 The Company seeks to apply this Policy in the recruitment, selection, training, appraisal, development and promotion of all employees. The Company offers goods and services in a fashion that complies with the spirit of this Policy.

12.2 This Policy does not form a part of any employment contract with any employee and its contents are not to be regarded by any person as implied, collateral or express terms to any contract made with the Company.

12.3 The Company reserves the right to amend and update this Policy at any time.