Policies
We are committed to delivering high-quality, reliable, and sustainable services to our customers, supported by a range of comprehensive policies. These policies are regularly reviewed and updated to ensure they remain relevant and effective. Below, you’ll find a selection of our most commonly requested policies, with additional ones available upon request.
Anti-Slavery Policy Statement
A. ORGANISATION
This statement applies to Technology Recovery Group UK Ltd (referred to in this statement as ‘the Organisation’). The information included in the statement refers to the financial year 2019/2020.
B. ORGANISATIONAL STRUCTURE
The main Head Office is at 10 Brook Office Park, Emersons Green, Bristol, BS16 7FL.The majority of employees operate from this office, departments include: Warehouse, Sales, Finance, Operations and Senior Management.
Technology Recovery Group UK Ltd, also operates from one office which is based in Poznan, Poland. This facility based at the following address: Kasztanowa 2 A, 64-320 Niepruszewok is used to repair all devices.
Technology Recovery Group specialise in the supply, installation, maintenance and support of rugged mobile data capture devices, phones, tablets, RF wireless networks, EPOS solutions, label printing solutions, voice picking solutions and network solutions. We offer over 80 combined years’ industry experience and a high level of technical resource in-house from our Central European and UK locations.
Demand for our product is consistently high throughout the year and is therefore not seasonal.
The labour supplied to the Organisation in pursuance of its operation is carried out in the UK & Poland.
C. DEFINITIONS
The Organisation considers that modern slavery encompasses:
- Human trafficking
- Forced work, through mental or physical threat
- Being owned or controlled by an employer through mental or physical abuse of the threat of abuse
- Being dehumanised, treated as a commodity, or being bought or sold as property
- Being physically constrained or to have restriction placed on freedom of movement
D. COMMITMENT
The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.
The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK and Poland.
E. SUPPLY CHAINS
In order to fulfil its activities, the Organisation’s main supply chains include those related to various suppliers within the UK.
F. POTENTIAL EXPOSURE
In general, the Organisation considers its exposure to slavery/human trafficking to be relatively limited, nonetheless it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.
G. STEPS
The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.
The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place:
We have developed a risk- based approach to the assessment of the possibility that Modern Slavery exists within TRG supply chain. Those undertaking the assessment have reviewed all suppliers. For each supplier information has been collected as to the identity of the actual supplier, the services or goods provided to TRG business, and the contract value. When undertaking the assessment, several factors were then considered which are broadly (1) location where the service or goods are supplied, (2) the industry sector from which the services or goods is provided, and (3) the labour practices specific to the industry and the location from which the particular services or goods are supplied.
H. KEY PERFORMANCE INDICATORS
The Organisation has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Organisation or its supply chains.
- Where possible, we build long-standing relationships with local suppliers and make clear our expectations of business behaviour.
- With regards to national or international supply chains, our point of contact is preferably with a UK or Ireland company or branch. We expect these entities to have suitable anti-slavery and human trafficking policies and processes.
- We have systems in place to encourage the reporting of concerns and the protection of whistle-blowers.
I. POLICIES
The Organisation has the following policies which further define its stance on modern slavery these can be found in our company handbook.
J. TRAINING
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business and supply chains, we will be providing training to our employees via our SharePoint portal. This will be completed by the end of next financial year, 31 July 2021.
K. SLAVERY COMPLIANCE OFFICER
The Organisation has a Slavery Compliance Officer, the Office Manager to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action regarding the Organisation obligations in this regard.
This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.
Date of approval: February 2024
Business Continuity Policy Statement
At Technology Recovery Group UK Ltd , we operate a Business Continuity Management System (BCMS) designed to identify and assess risks from foreseeable events that could affect our business. This system ensures effective planning for loss prevention, business resilience, and damage mitigation, based on thorough risk evaluation.
Our business continuity plans are developed and maintained to provide clear recovery objectives and essential information for use by senior management during significant incidents.
The directors are responsible for all aspects of our business continuity management system, ensuring the plans are regularly reviewed and adapted to meet the evolving needs of the business.
The senior management team ensures the system’s performance is reviewed, resources are allocated appropriately, and there is a commitment to continuous improvement.
The level of planning and resources deployed is proportionate to the assessed risks and their potential impact on critical business processes or assets. This approach ensures that our preparedness aligns with the identified risks.
Through these measures, TRG Solutions demonstrates its commitment to effectively managing potential disruptions and ensuring the continuity of business operations.
Data Protection Policy
1. Management Summary
The Data Protection Act 2018 is the UK’s implementation of the General Data Protection Regulation (GDPR). This Data Protection Policy forms the basis for complying with legal data protection requirements and ensures the protection of the processed personal data of Technology Recovery Group UK Ltd.
Data protection is fundamental to Technology Recovery Group UK Ltd’s operations, ensuring that all internal processes align with the principles of data protection by design and data protection by default.
Technology Recovery Group UK Ltd acts as both a data controller and a data processor. As a data controller, we manage personal data of our staff, subcontractors, suppliers, and customers. As a data processor, we provide cloud processing services for government and private sector customers.
Under GDPR, everyone responsible for processing personal data must follow strict rules called data protection principles to ensure data is:
- Processed lawfully, fairly, and transparently;
- Collected for specific, legitimate purposes;
- Minimally processed (only the data necessary for the specified purposes);
- Accurate and kept up to date;
- Stored no longer than necessary;
- Securely processed to protect against unauthorized or unlawful access, loss, destruction, or damage.
This policy defines Technology Recovery Group UK Ltd’s approach to handling personal data, including responsibilities, technical measures, and strategies for compliance with GDPR.
2. Principles
2.1 Policy Statement
Technology Recovery Group UK Ltd is committed to:
- Complying with the Data Protection Act 2018 and the UK GDPR.
- Respecting the rights of data subjects, including access, rectification, erasure, and portability of personal data.
- Being transparent and open with individuals whose data is processed, including providing clear privacy information.
- Obtaining active, informed consent for data processing where applicable, and ensuring all consents are recorded and auditable.
- Maintaining and regularly reviewing records of all personal data processing activities.
- Ensuring that any international data transfers (e.g., outside the UK or EU) comply with legal safeguards.
- Regularly assessing and evaluating the effectiveness of our data protection measures, including testing for confidentiality, integrity, and availability of data systems.
2.2 Management Commitment
The management of Technology Recovery Group UK Ltd considers this Data Protection Policy a key component of its corporate strategy. The Board has reviewed and fully supports the policy’s objectives and its alignment with business strategy.
2.3 Scope
This policy applies to all staff, contractors, sub-contractors, and suppliers. Suppliers are required to implement their own Data Protection policies that conform to the Data Protection Act 2018 or equivalent GDPR regulations if their main business location is outside the UK.
2.4 Data Protection Officer
The company’s Data Protection Officer (DPO) is responsible for ensuring compliance with data protection regulations and overseeing all legal, technological, and organizational matters. The DPO’s responsibilities include:
- Training staff in data protection, privacy, and cybersecurity measures;
- Ensuring active, informed consent is obtained and recorded for consent-based data processing activities;
- Maintaining records of data processing activities;
- Conducting privacy impact assessments, especially before new technology or procedures are implemented;
- Liaising with the Information Commissioner’s Office (ICO) and acting as the primary point of contact for reporting data breaches;
- Ensuring that any international data transfers are compliant with GDPR.
2.5 User Responsibilities
All employees are responsible for complying with this policy and ensuring personal data is processed in line with legal requirements.
3. Technical and Organizational Measures
3.1 Data Security
Technology Recovery Group UK Ltd takes the following technical and organizational measures to ensure the ongoing confidentiality, integrity, availability, and resilience of processing systems and services:
- Encryption of data at rest and in transit to prevent unauthorized access.
- Regular security reviews and audits of data processing activities and systems.
- Backup and restore capabilities to ensure data is recoverable in the event of loss or corruption.
- Regular testing and evaluation of business continuity plans, cybersecurity defenses, and data protection measures.
- Ongoing staff training on data protection and cybersecurity practices, ensuring employees are aware of threats like hacking, phishing, and malware.
- Access controls that restrict access to personal data to authorized personnel only.
3.2 Data Subject Rights
Technology Recovery Group UK Ltd is committed to upholding the rights of data subjects under GDPR, including:
- Right to access: Providing individuals with information about how their personal data is processed, upon request.
- Right to rectification: Correcting inaccurate personal data.
- Right to erasure: Deleting personal data upon request, where appropriate.
- Right to portability: Transferring personal data in a structured, commonly used, machine-readable format.
- Right to restrict processing: Limiting the use of personal data when necessary.
We maintain clear procedures for handling subject access requests (SARs) and ensuring requests are processed within statutory timeframes.
3.3 Consent-Based Processing
Where processing activities are based on consent, Technology Recovery Group UK Ltd ensures that:
- Consent is active, informed, and explicit, meaning individuals must take a clear action to provide their consent, which is then documented.
- Consents are auditable, allowing the company to prove when and how consent was obtained.
- Procedures for withdrawal of consent are in place and communicated to data subjects.
3.4 Data Transfers Outside the EU
If personal data is transferred outside the UK or EU, Technology Recovery Group UK Ltd ensures:
- Legal safeguards such as standard contractual clauses (SCCs) are in place to legitimize the transfer.
- Data subjects are informed about international transfers, and their rights are protected.
3.5 Records of Processing Activities
The company maintains detailed records of all personal data processing activities in compliance with Article 30 of the GDPR, including:
- Categories of data subjects and personal data processed;
- Processing purposes;
- Data retention periods;
- Security measures applied to protect the data;
- Third-party data sharing arrangements.
3.6 Testing and Assessment
Technology Recovery Group UK Ltd conducts regular testing, assessment, and evaluation of the effectiveness of the above measures to ensure continuous compliance with data protection regulations.
4. Data Protection Impact Assessments (DPIAs)
Before introducing new technology or processing activities that could pose a high risk to data subjects, Technology Recovery Group UK Ltd conducts a Data Protection Impact Assessment (DPIA). The DPO is responsible for overseeing the DPIA process and ensuring mitigating actions are taken to reduce risks.
5. Data Breaches
In the event of a data breach:
- The DPO must be notified immediately;
- The breach will be assessed, and appropriate action taken, including reporting to the Information Commissioner’s Office (ICO) within 72 hours of the breach;
- Data subjects affected by the breach will be informed without undue delay.
6. Disciplinary Consequences
Any breach of this Data Protection Policy may result in disciplinary action, up to and including termination of employment. Legal actions may also be pursued where appropriate.
Environmental Policy Statement
Technology Recovery Group UK Ltd supplies, maintains, and installs Data Terminals, Wireless Networks, Thermal Printing and Bar-Coding Data Collection Technologies. Technology Recovery Group UK Ltd recognises that the protection of the environment and the safety and health of its employees, its sub-contractors and any others affected by its operations are integral parts of the Company business performance and are a management priority.
For all areas where we operate, including activities undertaken both in the UK and Internationally, Technology Recovery Group UK Ltd is committed to:
Certifications and Legal Requirements: Achieving a high level of safety, health and environmental (SHE) performance, promoting the concept of sustainability, a safe and healthy working environment, and maintaining our certification to ISO 9001: 2008 and ISO 14001:2015, including provision for industry requirements. Complying fully with relevant enforcement agencies and non-statutory bodies. Meeting or exceeding all the environmental legislation that relates to the Company
Reducing E-Waste: Electronic waste is a growing global issue which Technology Recovery Group UK Ltd aims to minimise their contribution to. Technology Recovery Group have a dedicated team of technicians enabling a customer’s obsolete / unwanted hardware to be refurbished using existing materials; this reduces the demand for new devices which in turn lowers the environmental impact associated with manufacturing, resource extraction and transportation of new devices.
Environmental-Driven Decision Making: Integrating the consideration of environmental concerns and impacts into all our decision making and activities. Avoiding unnecessary use of hazardous materials and products and seek substitutions when feasible. Take all reasonable steps to protect human health and the environment when such materials must be used, stored and disposed of accordingly.
Process Approach and Improvement: Minimising waste by evaluating operations and ensuring they are as efficient as possible. Actively promoting recycling both internally and amongst employees, customers and suppliers. Minimising toxic emissions through the selection and use of its fleet and the source of its power requirement. Striving to continually improve our environmental performance and minimising the social impact and damage of activities by periodically reviewing our environmental policy in light of our current and planned future activities.
Supply Chain: Sourcing and promoting a product range to minimise the environmental impact of both production and distribution.
This document outlines our position on environmental issues and serves as a guide for our policies and practices related to conducting our business. We have taken this stance in order to make our commitment to the environment clear and allow us to effectively manage our environmental responsibility.
Health and Safety Policy Statement
At Technology Recovery Group UK Ltd, we are committed to complying with the Health and Safety at Work Act and maintaining a healthy and safe working environment for all employees and others who may be affected by our operations. Our approach focuses on promoting safe practices, preventing workplace risks, and providing clear guidelines to ensure the well-being of everyone involved.
Key Objectives
Our health and safety policy aims to:
- Provide a safe working environment: We are committed to ensuring that our workplace is healthy and safe for all employees.
- Conduct risk assessments: We carry out thorough assessments of potential health and safety risks to employees and others impacted by our activities, taking steps to minimise these risks wherever possible.
- Implement safe working practices: We continuously monitor and improve our working methods, processes, and environments to enhance health, safety, and welfare standards.
- Employee training: We ensure that all employees receive appropriate training to work safely and understand potential hazards and preventative measures.
- Response to health and safety concerns: We maintain clear procedures to address any health, safety, or welfare concerns raised by employees in a prompt and positive manner.
- Facilitate communication and consultation: We ensure that there are adequate arrangements for communication and consultation between management and employees on health and safety matters.
- Allocate necessary resources: We provide the resources required to implement our health and safety policy effectively.
Responsibilities
- Employer Responsibilities: Technology Recovery Group UK Ltd ensures that all legal obligations regarding health and safety are met and maintained, including regular updates and revisions to the policy.
- Employee Responsibilities: Health and safety is a shared responsibility, and all employees are expected to:
- Take reasonable care for their own health and safety and that of others who may be affected by their actions.
- Avoid intentionally or recklessly interfering with or misusing any equipment or processes provided for health, safety, or welfare purposes.
- Immediately report any injuries sustained at work and any situations or practices they believe are unsafe.
Reporting and Monitoring
We actively monitor our workplace and encourage employees to report any incidents, unsafe conditions, or concerns. Prompt responses will be made to address these reports and implement any necessary changes to maintain safety.
Policy Review and Documentation
Our health and safety policy is regularly reviewed and revised as necessary to ensure compliance with legal requirements and evolving best practices. The specific roles and responsibilities regarding health and safety are detailed in our Health and Safety documentation, which is available to all employees.
Information Security Policy Statement
Technology Recovery Group UK Ltd is committed to safeguarding the security and integrity of all information under its control. This policy aims to protect Technology Recovery Group UK Ltd and its affiliates, including employees and stakeholders, from unauthorised access, data breaches, and malicious attacks that could compromise sensitive information, damage critical systems, disrupt operations, or harm Technology Recovery Group’s reputation.
Commitment to Security
To meet these commitments, Technology Recovery Group UK Ltd has established an Information Security Management System (ISMS) that will cover all company operations and ensure compliance with relevant data protection legislation, including the requirements of ISO 27001. The ISMS will also aim to prevent significant risks of harm or distress arising from the release or loss of sensitive information.
Roles and Responsibilities
Technology Recovery Group UK Ltd has appointed a Privacy Officer and a Security Officer to oversee the performance of the ISMS. Additionally, the Security Committee is responsible for maintaining an internal control environment and ensuring that senior management monitors and evaluates the system’s effectiveness.
Risk Management and Incident Response
All information assets will be identified and assessed for potential risks, with designated owners responsible for implementing and maintaining appropriate security controls. Any breaches or security incidents will be thoroughly investigated, and corrective actions will be taken to prevent future occurrences.
Employee Responsibility
Every Technology Recovery Group UK Ltd employee, contractor, and third-party partner is responsible for adhering to the ISMS and reporting any known or potential security breaches. Failure to comply with this policy may result in disciplinary actions as outlined in the Technology Recovery Group Employee Handbook.
Review and Continuous Improvement
The ISMS will be subject to regular review by the senior management team, with results reported to the Board of Directors. Technology Recovery Group UK Ltd is committed to continuously improving its security posture to adapt to emerging threats and evolving business needs.
Quality Policy Statement
Principles
We are committed to delivering the highest quality service in mobile technology across the UK, EU, and North America. Our quality management practices enable us to build and maintain strong relationships with customers, partners, and colleagues.
We prioritise understanding customer needs from the outset, ensuring our processes are aligned with best practices to deliver exceptional service. Regular feedback and process reviews will inform continuous improvements, helping us refine and enhance our service offerings.
Our company fosters a culture of improvement by empowering teams and individuals, supporting both personal and professional growth. We emphasise innovation and accountability, encouraging our people to develop and implement solutions in mobile technology and managed services.
Policy
- Customer Focus: Regular reviews of service delivery, relationship management, and customer satisfaction will be conducted at multiple levels, with engagement from service managers to the CEO.
- Leadership: Scheduled management meetings, alongside quarterly, half-yearly, and annual performance updates for all employees, ensure transparency and senior management involvement across locations.
- Engagement: We cultivate a culture of engagement through an employee-led structure, distinct from senior management. Senior leadership will regularly engage with teams and locations, ensuring open communication across the business.
- Process Approach: Operational activities are managed through internal systems, with improvements driven by customer feedback. Efficiency will be measured through our systems, ensuring all process changes are data-driven.
- Improvement: Management and customer reviews will drive documented improvements, overseen by the Head of Business Intelligence and Director of Support Services, while the Technical Services team ensures consistent delivery.
- Decision Making: Business information from sales and finance systems will guide performance reviews and decision-making processes. Operational and customer service performance will be monitored daily to ensure consistent improvement.
- Relationship Management: We build close partnerships with customers through our Account Directors, Service Managers, and Sales Management teams. We measure the success of these relationships through customer engagement, service expansion, and the longevity of partnerships.
Sustainability Policy Statement
At Technology Recovery Group UK Ltd, we are dedicated to making a meaningful and lasting impact on how IT solutions are provided. We offer a full circular procurement model that benefits both our customers and the environment, with a focus on protecting future generations. Our approach empowers customers to improve education, health, and the quality of life in the UK, while helping businesses increase productivity and value.
Technology Recovery Group UK Ltd is committed to pursuing greater sustainability in all areas of our business. This includes fulfilling environmental, social, and economic responsibilities. We have aligned our operations with the UN Sustainable Development Goals (SDGs) and developed a Sustainability Framework with 10 focus areas, under the theme “Driving Digital Sustainability.”
Environmental Commitments:
- Circular Economy (SDG 12: Responsible Consumption and Production)
We prioritise the repair, reuse, and responsible consumption of technology, with warranties and support that extend product lifecycles. - Sustainable Procurement (SDG 11: Sustainable Cities and Communities)
We partner with suppliers and stakeholders who share our commitment to sustainable practices. - Net Zero (SDG 13: Climate Action)
Our goal is to achieve Net Zero carbon emissions by 2050. - Environmental Protection & Biodiversity (SDGs 14 and 15: Life Below Water, Life on Land)
We protect and support biodiversity in all our operations. - Zero Waste (SDG 15: Life on Land)
We aim for a zero-waste policy by optimising resource use and recycling.
Social Sustainability:
- Sustainable Solutions (SDG 9: Industry, Innovation, and Infrastructure)
We provide innovative solutions that support long-term social and environmental goals. - Social Value (SDG 10: Reduced Inequalities)
We contribute to reducing inequalities in society by creating inclusive opportunities. - Wellbeing and Engagement (SDG 3: Good Health and Well-being)
We promote a positive working environment that values the well-being of all stakeholders. - Protecting Human Rights (SDG 8: Decent Work and Economic Growth)
We are committed to upholding human rights throughout our operations and supply chain. - Closing the Digital Gap (SDG 4: Quality Education)
We aim to bridge the digital divide by ensuring access to technology and education for all.
Governance and Implementation:
The board of directors at Technology Recovery Group UK Ltd takes overall responsibility for the company’s sustainability strategy. Our senior management team ensures that these strategies are integrated into all business operations, addressing both risks and opportunities that may affect our sustainability goals.
We are guided by the following core values in shaping our business strategies and key decisions:
- Sustainability
- Dedication
- Customer Service
- Belief in People
- Integrity
- Innovation
By embedding these values into our management approach, we ensure:
- Transparent and fair engagement with all stakeholders, promoting an understanding of sustainability issues.
- A commitment to going beyond minimum legal compliance, striving for meaningful sustainability impacts.
- Accountability for the entire lifecycle of our business activities, ensuring responsible management.
- Clear and concise communication of our sustainability efforts and progress to all stakeholders.
The senior management team is responsible for developing policies and allocating resources to ensure continued progress on our sustainability objectives, enhancing business opportunities and building stakeholder confidence.
We recognise that the success of this policy depends on the active commitment and participation of all our stakeholders.
Sustainable Procurement/Supply Chain Policy
At Technology Recovery Group UK Ltd, our commitment to sustainability is embedded in our mission to foster responsible growth. We actively invest in sustainable practices across our supply chain, processes, and our people, to ensure our procurement activities deliver positive, long-lasting outcomes. We encourage our suppliers, partners, and subcontractors to align with our sustainability goals.
As a forward-thinking provider of mobile technology services, we are dedicated to leading by example in promoting sustainability within our supply chain and embracing the principles of a circular economy. Building on our legacy of innovative services, we strive to share our knowledge for the greater good of the planet. To achieve this, we are implementing the following key strategies:
| Aspect | Strategy |
|---|---|
| Carbon Emissions | Measure and reduce carbon emissions with a plan to achieve Net Zero by 2050, including interim milestones and transparent reporting. |
| Circular Economy | Promote repair, reuse, and recycling, aiming for Zero to Landfill, and fostering sustainability across the industry. |
| Customers | Engage customers through events to promote sustainable practices like reducing energy use, extending equipment life, and recycling. |
| Environmental Management | Minimise environmental impacts in supply chain operations by working with suppliers and subcontractors to ensure compliance and sustainability. |
| Ethical Sourcing | Source materials, products, and services ethically, with processes to encourage employees to report any concerns about unethical practices. |
| Labour Standards | Raise awareness of acceptable labour standards and the risks of modern slavery within TRG and throughout the supply chain. |
| Materials Usage | Reduce waste and transition to sustainable materials in products and packaging, encouraging suppliers and customers to adopt similar practices. |
| Payment | Ensure timely payments to all supply chain partners according to agreed terms. |
| People | Focus on local recruitment, providing training, apprenticeships, and work experience to support community development. |
| Supporting Smaller Suppliers | Collaborate with SMEs and local businesses that share TRG’s sustainability goals, offering them opportunities in our supply chain. |
| Supply Chain Management | Implement robust onboarding and regular reviews of suppliers to ensure alignment with TRG’s sustainability values and goals. |
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