1. Privacy & Cookies Policy
What we collect
While running and operating this website, we may collect and process certain data and information relating to you and how you use our site, like:
- Details of visits to our websites and the pages and resources you access. That includes (but isn’t limited to) traffic data, location data and other communication data that might help us understand how visitors use our website
- Information that visitors give us through the forms on our website
- Information given to us when visitors communicate with us electronically for any reason
How we use it
We use the information we collect for our own use in developing our website and also occasionally by advertisers on our site. We might also use it to:
- Provide you with information about our website, products or services you request from us
- Give you information on other products we think might interest you
- Meet our contractual obligations to you
- Notify you about any changes to our website, including improvements and service or product changes that might affect our site
How we store it
We store data that’s provided to us on our secure servers. Details about any transactions entered into on our site are encrypted to make sure they’re kept safe.
But the transmission of data via the internet is never totally secure, so we can’t guarantee the security of data that’s sent to us electronically - it is entirely at your own risk. Similarly, where we’ve given you (or you’ve chosen) a password to access parts of our site, you’re responsible for keeping this password confidential.
Disclosing your information
Where applicable, we may share your personal information to any member of our group. This includes to our subsidiaries, our holding company and its other subsidiaries.
We may also share your personal data with third parties if:
- We sell any or all of our business and/or our assets to a third party
- We’re legally required to disclose your information
- It will assist fraud reduction and minimise credit risks
You might find links to third-party websites on our site. These websites should have their own privacy policies for you to check. We don’t have any responsibility or liability for their policies, as we don’t have any control over them.
Accessing your information
The Data Protection Act 1998 gives everyone the right to access any personal information that’s held about them. To ask for a copy of the information we hold about you or to ask any questions – just contact us at firstname.lastname@example.org.
Cookies are small files which are sent to your web browser and stored on your computer’s hard drive. We use a few different types of cookies:
- Strictly necessary cookies that we need to operate our website. These let you, for example, log into secure areas of our website or use a shopping cart.
- Analytical/performance cookies that let us recognise, count and see how visitors use our website. It lets us improve the way our website works.
- Functionality cookies which are used to recognise you when you return to our website. This lets us personalise content for you.
- Targeting cookies that record your visit to our website, the pages you’ve visited and the links you’ve followed. We use this to make our website and the advertising on it more relevant to your interests. We might also share this information with third parties for the same reason.
You can control and delete cookies whenever you like – for details see aboutcookies.org. You can also delete any cookies that are already on your computer or set most browsers to prevent them from being placed. If you do this though, you might have to manually adjust some preferences every time you visit a site. Plus, some services and functionalities may not work.
2. COVID-19 Policy
VCCP Business COVID-19 risk assessment
VCCP Partnership (Teamspirit’s parent company) has published its own COVID-19 risk assessment. It shows how our company’s complying with government guidance to manage the risk of COVID-19, and prioritising the safety and wellbeing of our staff, clients and visitors.
Staying COVID-19 secure in 2020 certificate
We’ve complied with the government's guidance on managing the risk of COVID-19.
3. Responsible sourcing policy
[responsible sourcing policy body]
Chime (Teamspirit’s holding company) and its companies operate in many markets and countries throughout the world. In all of them, we’re committed to using our creativity, relationships and work fairly. Whether that’s by creating social cohesion, encouraging kindness towards each other and our planet or sharing our skills to deliver social good.
As set out in our Responsible Business Code, we act responsibly and conduct our business with honesty and in good faith. We set ourselves high standards in our business practices and work with our value chain partners and suppliers to make sure we meet the principles set out below.
It’s the Chime Group’s policy to:
- Procure goods and services from reputable suppliers with established processes that reflect our Responsible Business Code and are consistent with this policy
- Establish and maintain processes that make sure our suppliers are selected based on how well they follow this policy
- Establish and maintain processes to monitor the compliance of our existing supply chain with this policy
- Drive continuous improvement, both in our own procurement practices and by encouraging our suppliers and wider value chain partners to develop practices consistent with our Responsible Business Code and this policy.
The principles in this policy aren’t exhaustive and shouldn’t be used to prevent suppliers from going over and above them. Instead, it should be used as a helpful guide for suppliers, not as a change or replacement to any specific contractual requirements. If suppliers have agreed to stricter or more detailed requirements than those in this Responsible Sourcing Policy, we expect them to meet those contractual requirements.
Who is responsible?
The Chime Board is accountable for the approach to business ethics set out in our Responsible Business Code. It’s also delegated the responsibility of establishing a procurement approach consistent with our Code to the Executive Board.
The Executive Board has set out the high-level principles to be adopted by the Chime Group companies in this policy. But the implementation of this policy and the operation of procurement at an agency level is the responsibility of each division. It’s up to them to establish their own processes and ensure compliance.
Chime’s internal audit team verifies compliance with our operational standards and reports directly to the Chime Board.
The 8 principles set out below are anchored in internationally recognised standards, including the UN Guiding Principles on Business and Human Rights, the United Nations Global Compact and the Universal Declaration of Human Rights. Suppliers must follow these principles at all times.
The Chime Group aims to be a good partner in return and will work with suppliers to support any necessary improvements and encourage ongoing development both by the Chime Group and its supply chain.
Compliance with laws and regulations
We expect suppliers to:
- Conduct their business in full compliance with governing laws, rules and regulations of national or, for those with international reach, that could be seen as connected with their business.
- Follow the Chime Group Anti-bribery and Corruption Policy.
- Make sure all business and commercial dealings are transparent and accurately recorded in the supplier’s records.
- Make sure all conflicts of interest are disclosed and managed.
Workers’ health and safety is protected
We expect suppliers to:
- Provide a safe and healthy workplace, support the wellbeing of their employees and prevent accidents and injury as a result of the employer’s operations.
- Manage health and safety risks systematically in accordance with applicable laws and regulations and international standards.
Fair and equitable employment
We expect suppliers to:
- Guarantee that the fundamental rights enshrined in the Universal Declaration of Human Rights and workers’ rights stated within the ILO Conventions are upheld.
- Follow principles which ensure fair wages (preferably paying at least the relevant living wage) and decent working hours; the right to freely chosen labour; protection of young workers and no use of child labour.
- Monitor and mitigate the risk of modern slavery within their own business and supply chain and to take steps to comply with applicable laws, regulations and international standards.
- Foster a culture of non-discrimination, equality of opportunity and humane treatment for all in a workplace free of harassment and abuse, and to monitor progress.
Suppliers should not discriminate against any worker based on age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex, sexual orientation, or any other legally protected characteristic.
Management of environmental impacts
We expect suppliers to:
- Operate in an environmentally responsible and efficient manner by identifying, managing, and reducing greenhouse gas emissions, water and waste and other adverse impacts on the environment.
- Systematically manage environmental risks to ensure necessary measures are taken to prevent pollution, conserve natural resources, safeguard biodiversity and take all reasonable measures to prevent any accidental spills/releases.
Confidentiality and data protection
We expect suppliers to:
- Respect data belonging to others, preserve confidentiality and data subjects’ individual rights.
- Have in place appropriate policies, contract terms and procedures (including procedures to manage and resolve breaches), and to be able to demonstrate that they are aware of the data they process, and that such personal data is processed in compliance with applicable laws and regulations and international standards.
We expect suppliers to:
- Demonstrate they have effective, industry-standard best practice security controls in place to protect all customer information that is stored or handled by their systems in providing services to us.
- Demonstrate they conduct routine security assessments on their systems and processes.
We expect suppliers to:
- Have appropriate insurance policies to cover claims and liabilities arising from the goods and/or services being provided to us with appropriate limits, compliant with national requirements.
- Have the following policies in place: broad form public liability insurance, and employer's liability insurance / worker’s compensation insurance.
We expect suppliers to:
- Use trading terms based on written contracts which specify mutually agreed pricing and payment conditions.
- Demonstrate fair treatment of their supply chain.
The Chime Group considers training to be vital in ensuring compliance with the principles set out above. Suppliers should maintain accurate records (including records of training undertaken) to demonstrate compliance with this Responsible Sourcing Policy.
The Chime Group reserves the right to carry out appropriate audits to obtain evidence of suppliers’ compliance to this Responsible Sourcing Policy.
Suppliers are responsible for prompt reporting of actual or suspected violations of law, this Responsible Sourcing Policy or any breach of contractual terms agreed with the Chime Group. This includes violations by any employee or agent acting on behalf of the Supplier.
Upon contracting with a Chime Group company, all suppliers will be asked to sign the following statement:
The undersigned acknowledges their understanding of, and their adherence to this Responsible Sourcing Policy. Suppliers are expected to take the necessary corrective actions to promptly remedy any non-compliance. Chime Group company reserves the right to terminate its business relationship with any Supplier who is unwilling to comply with this Responsible Sourcing Policy.
Have a question?
If you need any help or want more detail on our Responsible Sourcing Policy, reach out to our Head of Governance & Company Secretary Chime Central at email@example.com.
4. Commitment to ESG
It’s clear from our purpose, to transform the world of finance for the better, that ESG means a lot to us. In everything we do – from the work we produce to the way we interact with one another – we believe in responsible action.
Internally, we’re focused on three core areas within the business:
- Colleague wellbeing
- Climate action
Externally, we’re committed to using our talent and skill to address critical global issues, working with clients and others in the industry to help change things for the better. This includes an increased focus on sustainability for the Chime Board.
We also encourage our team to use their services as a force for good, which includes pro and low bono work. These projects are demonstrated through our yearly For The Better Awards.
Volunteering is close to our hearts too, so we promote and facilitate individual team members or groups to do so. That might be giving them the time to get their hands dirty or through our Give As You Earn scheme, helping them support causes that are important to them.
Want to ask something about ESG?
For more information on our Sustainability strategy and actions, please get in touch with Jo Parker our Group COO & CEO firstname.lastname@example.org.
5. Modern Slavery Statement
Our modern slavery and human trafficking statement.
This statement has been made according to the Modern Slavery Act 2015 (the 'Act') and has been ratified by the Boards of Chime Group Holdings Limited, Chime Group Limited, VCCP Group LLP and CSM Sport and Entertainment LLP.
Companies in the Group that are required to issue this statement for the financial year ended 31 December 2019 are Chime Group Holdings Limited, Chime Group Limited, VCCP Group LLP and CSM Sport and Entertainment LLP.
We do not tolerate any form of modern slavery or human trafficking in any part of our business and are committed to carrying on our business in a way which respect the rights of individuals in the communities where we operate. We have taken, and are continuing to take, steps to ensure that our businesses identify risk areas in their supply chains and implement policies and procedures to eliminate those risks.
The Board of Directors of Chime Group Holdings Limited are responsible for the overall strategic direction of the Group. That includes making sure that identification and risk management systems, including the risk of slavery and human trafficking in our business or supply chain, are robust and appropriate.
Our Chime Group Responsible Business Code sets out the high-level behaviours we expect our agencies, staff and trading partners to uphold. In it we state that:
“We will continue to strive to make a positive contribution to society and the environment by: maintaining high standards of marketing ethics; respecting human rights; respecting the environment; supporting community organisations; supporting employee development; and managing significant sustainability risks in our supply chain.”
Our Responsible Business Code, Staff Code of Conduct and other policies aim to support and uphold the United Nations’ Guiding Principles on Business and Human Rights. All operating companies must follow these Codes. Implementation is determined at division level and is each agency’s responsibility.
To raise awareness about the risks of modern slavery within our business and supply chain, we have provided targeted training and we will be extending this training to other teams across the Group in the future.
Notwithstanding the diverse nature of the services offered by our Group and the significant number of individuals involved in delivering those services, the Group continues to consider our business low risk for modern slavery and human trafficking issues.
All our businesses have comprehensive employment policies and practices, including flexible working, diversity and equal opportunities and grievance policies which minimise the risk of modern slavery.
Whilst our businesses engage with a broad range of suppliers worldwide, we don’t consider our supply chain to be high risk for the reasons set out below.
We’ve assessed our supply base to identify any high risk suppliers or areas for focus. This assessment included mapping by agency, category, spend and geography.
Suppliers used by the Group were identified as typically falling within the following categories: professional services, media buying, logistics delivery, venue hospitality, security services, transport and travel, cleaners and maintenance. Goods that we purchase include items such as raw materials, merchandise, utilities and general office equipment.
Overall, the risk assessment demonstrated that most of the Group’s primary tier suppliers are in low-risk countries.
We do due diligence on all our suppliers above a minimum threshold. The due diligence process includes conducting searches using a leading compliance tool which enables us to access data from a wide variety of data points on companies around the world. Once a supplier has been accepted, we continue to monitor for any changes through the compliance tool.
Through investment in technology (particularly in financial management systems) we’ve been able to monitor our supply chain more effectively. This has enabled our businesses to procure supplies more efficiently and reduced the number of suppliers it buys from. This allows us to better understand both our primary tier supply chain and the source of supplies further down our chain. So we can scrutinise and provide assurance to our clients and stakeholders.
Whilst we are confident there is limited risk in our primary tier suppliers, we acknowledge there is still work to be done to understand risks further down the supply chain.
We continue to focus on areas where we think risks may be higher, principally where we operate in geographies where our knowledge of, and relationship with, our suppliers is less deeply embedded.
We continue to focus on ensuring that our processes are robust, systematic, and assess the risk of modern slavery within our supply chain. Training and ensuring the application of consistent high standards remain a priority.
In addition to the above, we maintain a third party managed whistleblowing helpline throughout the business to which all employees have access (including those in non-UK offices) if they feel they cannot raise their concerns internally. In our periodic reminders to staff, we include the reporting of concerns in relation to supply chain management (including those relating to slavery and human trafficking).