Legal pages

Copyright (c) [2009]-[present][https://www.elt-consultants.com/ full name Wendy Arnold & Co. Ltd trading as ELT Consultants ©

Subject to the express provisions of this disclaimer:

(a)    Wendy Arnold from ELT Consultants (c) owns and controls all the copyright and other intellectual property rights on our website and the material on our website.

(b)    All the copyright and other intellectual property rights on our website and the material on our website are reserved.

(c)    Wendy Arnold from ELT Consultants ©  owns and controls all the copyright on the website when it comes to articles, images, materials, ideas, and crafts, and only the people who participated as guests and article writers on ELT can reuse and republish the content.

License to use website

1.1    You may:

View pages from our website in a web browser.

Downloading and printing pages from our website is strictly forbidden.

1.2    Except as expressly permitted by the website owner or the other provisions of this disclaimer, you must not download any material from our website or save any such material to your computer.

1.3    You may only use our website for [your own personal purposes], and you must not use our website for any other purposes.

1.4    Unless you own or control the relevant rights in the materials or articles, you must not:

• Republish material from our website (including republication on another website);
• Sell, rent, or sub-license material from our website;
• Exploit material from our website for a commercial purpose;
• Redistribute any material from our website.

We reserve the right to restrict access to areas of the website, at our discretion; you must not circumvent or bypass, or attempt to circumvent or bypass, any access restriction measures on our website.

Acceptable use

You must not:

• Use our website in any way or take any action that causes, or may cause, damage to the website or impairment of the performance, availability, or accessibility of the website;
• Use our website in any way that is unlawful, illegal, fraudulent, or harmful, or in connection with any unlawful, illegal, fraudulent, or harmful purpose or activity;
• Use our website to copy, store, host, transmit, send, use, publish or distribute any material which consists of (or is linked to) any spyware, computer virus, Trojan horse, worm, keystroke logger, rootkit, or other malicious computer software;
• Conduct any systematic or automated data collection activities (including without limitation scraping, data mining, data extraction, and data harvesting) on or in relation to our website without our express written consent;
• Access or otherwise interact with our website using any robot, spider, or other automated means [except for the purpose of search engine indexing];
• Violate the directives set out in the robots.txt file for our website;
• Use data collected from our website for any direct marketing activity (including without limitation email marketing, SMS marketing, telemarketing, and direct mailing)].

You must not use data collected from our website to contact individuals, companies, or other persons or entities.

You must ensure that all the information you supply to us through our website, or in relation to our website, is [true, accurate, current, complete, and non-misleading].

Disclaimer

This disclaimer governs your use of this website

By using our website, you accept this disclaimer in full; accordingly, if you disagree with this disclaimer or any part of this disclaimer, you must not use our website.

Our website uses cookies; by using our website or agreeing to this disclaimer, you consent to the use of cookies in accordance with the terms of our privacy and cookies policy.

Limited warranties

We do not warrant or represent:

• The completeness or accuracy of the information published on our website;
• That the material on the website is up to date;
• That the website or any service on the website will remain available.

All the advice on this website comes from professional educators, but we do not represent any official educational institutions or universities, we are a nonprofit organization, so we cannot be held accountable for any issues or failed teaching methods or professional development trainings you might attend on this website.

We reserve the right to discontinue or alter any or all of our website services, and to stop publishing on our website, at any time in our sole discretion without notice or explanation; and save to the extent expressly provided otherwise in this disclaimer, you will not be entitled to any compensation or other payment upon the discontinuance or alteration of any website services, or if we stop publishing content on our website.

To the maximum extent permitted by applicable law and subject to Section titled limited warranties, I exclude all representations and warranties relating to the subject matter of this disclaimer, our website, and the use of our website.

Limitations and exclusions of liability

Nothing in this disclaimer will:

• Limit or exclude any liability for death or personal injury resulting from negligence;
• Limit or exclude any liability for fraud or fraudulent misrepresentation;
• Limit any liabilities in any way that is not permitted under applicable law;
• Exclude any liabilities that may not be excluded under applicable law.

The limitations and exclusions of liability set out in this titled limitations and exclusions of liability and elsewhere in this disclaimer:

• Are subject to Section limitation and exclusions of liability;
• Govern all liabilities arising under this disclaimer or relating to the subject matter of this disclaimer, including liabilities arising in contract, in tort (including negligence), and for breach of statutory duty, except to the extent expressly provided otherwise in this disclaimer.

We will not be liable to you in respect of any losses or issues arising out of third-party links, institutions we work for, or any educational digital tools we share on our website.

To the extent that our website and the information on our website are provided free of charge, we will not be liable for any loss or damage of any nature.

We will not be liable to you in respect of any losses arising out of any event or events beyond our reasonable control.

We will not be liable to you in respect of any business losses, including (without limitation) loss of your damage to profits, income, revenue, use, production, anticipated savings, business, contracts, commercial opportunities, or goodwill.

We will not be liable to you in respect of any loss or corruption of any data, database, or software.

We will not be liable to you in respect of any special, indirect, or consequential loss or damage.

Variation

We may revise this disclaimer from time to time.

The revised disclaimer will apply to the use of our website from the time of publication of the revised disclaimer on the website.

Severability

If a provision of this disclaimer is determined by any court or other competent authority to be unlawful and/or unenforceable, the other provisions will continue in effect.

If any unlawful and/or unenforceable provision of this disclaimer would be lawful or enforceable if part of it were deleted, that part will be deemed to be deleted, and the rest of the provision will continue in effect.

Law and jurisdiction

This disclaimer shall be governed by and construed in accordance with Serbian law.

Any disputes relating to this disclaimer shall be subject to the exclusive jurisdiction of the courts of Serbia.

Statutory and regulatory disclosures

This website is owned and operated by Wendy Arnold

You can contact us at [email protected]

Credit

This document was created using a template from SEQ Legal.

Privacy policy

At ELT Consultants © accessible from https://www.elt-consultants.com/ one of our main priorities is the privacy of our visitors. This Privacy Policy document contains types of information that is collected and recorded by ELT Consultants ©  and how we use it.

If you have additional questions or require more information about the Privacy Policy, do not hesitate to contact us.

This policy is not applicable to any information collected offline or via channels other than this website.

Anti-fraud and corruption global policy statement

Wendy Arnold & Co. Ltd trading as ELT Consultants has a ‘zero tolerance’ policy towards fraud, bribery and corruption.

We are committed to:

• developing an anti-fraud culture across the organisation 
• seeking to minimise the opportunities for fraud, bribery and corruption 
• having effective systems, procedures and controls in place to enable the prevention and detection of fraud, corruption and bribery
• ensuring that its Associate Consultants are aware of the risks of fraud, bribery and corruption and understand their obligations to report any actual or suspected incidents of fraud, bribery or corruption
• taking all reports of fraud, bribery and corruption seriously, and investigating them proportionately and appropriately 
• meeting its obligations to report any incidents of fraud, bribery and corruption to appropriate external authorities.

Complaints

We encourage anyone with comments or complaints about our products or services to contact us. 

We are committed to:

• taking all comments and complaints seriously and investigating them proportionately and appropriately
• ensuring that our Associate Consultants are aware of the complaints policy and are clear about their responsibilities when handling, resolving and reporting on complaints
• apologising when a mistake has been made, explaining what has happened and what will be done next and taking action to remedy situations wherever practical
• drawing upon customer complaints and feedback to identify how we can improve our services. 

Countering terrorist financing, anti-money laundering and sanctions global policy statement

Wendy Arnold & Co. Ltd trading as ELT Consultantsis committed to complying with all relevant UK legislation and legislation in the countries where it operates. This includes counter-terrorism and money laundering legislation, and applicable sanctions. Our resources must not be used to support criminal or terrorist purposes or in any way that breaches applicable sanctions.  

We will assess the risks of becoming involved with terrorism and money laundering, and of breaching applicable sanctions. We will put in place proportionate measures to manage those risks, while continuing to work in difficult and challenging places. 

We are committed to:   

• having systems, procedures and controls in place to ensure that it manages the risk of becoming involved in financing or supporting terrorist activity, money laundering, or breaching sanctions
• for the highest risk transactions, checking that those the Wendy Arnold & Co. Ltd trading as ELT Consultants funds or works with are not on any lists of proscribed terrorist groups or persons, financial sanctions lists or other regulatory compliance lists, and assessing the risks if they are
• training relevant Associate Consultants so that they have an awareness of the risks related to terrorist activity, money laundering, and breaching sanctions
• meeting its obligations to report to external authorities. 

We require all those receiving Wendy Arnold & Co. Ltd trading as ELT Consultants funds to act in accordance with this policy to ensure that our funds and assets are not used to finance or support terrorist activity or in breach of sanctions. 

Equality

Working effectively with diversity is an essential part of our mission. We are committed to ensuring that there is no unjustified discrimination in the recruitment, retention, treatment, training and development of Associate Consultants on the basis of age, disability, gender including transgender, HIV/AIDS status, marital status including civil partnerships, pregnancy and maternity, political opinion, race/ethnicity, religion and belief, sexual orientation, socio-economic background, spent convictions, trade union activity or membership, work pattern, having or not having dependants or on any other grounds which are irrelevant to decision making.

We aim to abide by and promote equality legislation. We follow both the letter and the spirit of the law in this area. We try to avoid unjustified discrimination which we recognise is a barrier to equality, diversity, inclusion and human rights.

We are committed to:

• understanding, valuing and working with diversity to enable fair and full participation in its work and activities
• ensuring that there is no unjustified discrimination in its recruitment, selection, performance management or other processes
• promoting equality; this includes conducting equality screening and impact assessments of policies and functions 
• treating individuals with whom it works with fairness, dignity and respect
• playing its part in removing barriers and redressing imbalances caused by inequality and unjustified discrimination.

Financial management and reporting

We have annual audited accounts for Wendy Arnold & Co. Ltd trading as ELT Consultants.

We are committed to:

• operating effective internal controls that safeguard, channel and record resources as intended, and support the achievement of its charitable objectives
• using its resources efficiently, economically and effectively
• giving timely, transparent and fair accounts of its use of resources.

Health and safety

We acknowledge our duty of care to ensure a safe place to work and visit for our Associate Consultants, customers and visitors. We will, where reasonably practicable, follow UK standards, guidance and codes of good practice where these offer enhanced standards of health and safety.

Health and safety is everyone’s responsibility as well as being a particular responsibility for all levels of management. Wendy Arnold & Co. Ltd trading as ELT Consultants expects everyone to be aware of their role in workplace safety.

We aim to ensure that all Associate consultants and those who work with the Wendy Arnold & Co. Ltd trading as ELT Consultants foster an attitude of good practice and co-operation in order to achieve high standards of health and safety.

We are committed to:

• achieving and maintaining good standards in its health and safety performance
• monitoring and reviewing its systems and procedures to ensure their suitability, adequacy and effectiveness
• ensuring all Associate consultants play their part in meeting Wendy Arnold & Co. Ltd trading as ELT Consultants health and safety standards
• enabling Associate Consultants to comply with the Wendy Arnold & Co. Ltd trading as ELT Consultants health and safety standards
• providing suitable and sufficient information, instruction, training and facilities to ensure all Associate Consultants are aware of, and equipped to carry out, their health and safety responsibilities 
• ensuring that those contracted to Wendy Arnold & Co. Ltd trading as ELT Consultants are aware of, and satisfactorily discharge, their health and safety roles and responsibilities.

Information security and privacy

We collect and use personal data to offer people information, products and services. This policy will apply in all locations where we operate, to all forms of information and to all systems used to collect, store, process or transfer information.

Wendy Arnold & Co. Ltd trading as ELT Consultants applies the UK Data Protection Act 2018 as a global privacy standard together with local data protection law in the countries where it operates. In countries where the UK Data Protection Act 2018 conflicts with local law, local law that meets internationally accepted privacy principles will take precedence.

We are committed to:

• performing privacy impact assessments to protect the privacy and rights and freedoms of its customers and employees
• protecting the confidentiality, integrity and availability of the information it collects, stores, transfers and processes in accordance with UK law and international good practice, and to meeting its legal requirements and contractual obligations
• explaining why it needs personal information, only asking for the personal information it needs and only sharing personal information within Wendy Arnold & Co. Ltd trading as ELT Consultants and with other organisations as necessary or where the person concerned has given their consent
• clearly and openly communicating to its customers and employees the purposes for processing their personal information, including the legal bases for processing and limiting the purposes to only what has been communicated or where there is a legal obligation
• allowing people to request access to the personal information it holds on them and to complain if they believe their information has been mishandled
• not keeping personal information for longer than necessary
• taking measures to protect the rights and freedoms of individuals whose personal information may be transferred to countries with differing data protection laws
• ensuring that actual or suspected breaches of information security are reported and investigated
• assessing the maturity of its information security controls annually
• applying these standards to its supply chain and delivery partners.

Media and Social Media

We recognise that appropriate use of media and social media contributes to Wendy Arnold & Co. Ltd trading as ELT Consultantsaims.

We use media and social media in two main ways: 

• to promote Wendy Arnold & Co. Ltd trading as ELT Consultantsand its services 
• to engage directly with audiences through a range of digital and learning channels including personal channels used in a professional capacity.

We are committed to:

• maintaining a professional social media presence, with Associate Consultants abiding by our Code of Conduct and other relevant policies and guidance 
• ensuring the ELT consultants official media and social media presence is readily identifiable through appropriate branding
• communicating with its media and social media audiences and answering their queries in a timely manner
• communicating to Associate Consultants the rules they must follow when identifying themselves as Wendy Arnold & Co. Ltd trading as ELT Consultants sub-contractors on social media.

Partnerships

We seek to work with partners who are aligned with our values, reputation, brand and charitable objectives.  

When selecting partners, we consider both the benefits and disbenefits of each partnership opportunity. This includes an assessment of any financial, legal and reputational risks. Specific decisions on entering into any partnership will depend on the reputation and practices of the individual organisation involved, and on the partnership making a significant contribution to the charitable objectives of Wendy Arnold & Co. Ltd trading as ELT Consultants.

When working with partners, we will do so in accordance with our legal obligations.

We are committed to ensuring that its partnerships:

• align Wendy Arnold & Co. Ltd trading as ELT Consultantswith organisations that are consistent with its values, reputation and brand
• are open and transparent, with written agreements in place
• respect appropriate use of the partners’ and of Wendy Arnold & Co. Ltd trading as ELT Consultantsintellectual property rights
• comply with relevant external legal frameworks

Records management policy statement

We recognise our obligation to create and maintain records which document our activities, to support good governance and to comply with legal and statutory requirements, in particular the Freedom of Information Act 2000, the Public Records Act 1958, the Data Protection Act 2018 and the General Data Protection Regulation.

We recognise that records form part of our corporate memory and are an important organisational asset. This applies to all records, in all media, which are created, received or maintained by our Associate Consultants, irrespective of their contractual status, in the course of ELT Consultants business. Records and documentation created through partnerships are also subject to contractual record keeping requirements.

We are committed to:

• ensuring that records are created to provide evidence of its decisions and activities
• maintaining record keeping systems to support the integrity and reliability of records
• developing and maintaining policy and procedures for the review and timely disposal of records in line with organisational requirements, legal obligations and historical value
• protecting records from unauthorised alteration or loss and providing an audit trail to record the movement and use of records
• setting principles and standards which govern access to records and reviewing information for sensitive issues
• ensuring that records which are essential to business continuity are identified and protected.

We require all Associate Consultants to ensure their behaviour is consistent with these policies. We also require that clients, customers, partners and suppliers are made aware of this policies and operate within it.

We will provide adequate and appropriate resources to implement these policies and will ensure it is communicated and understood.

We will review this global policy statement annually to reflect new legal and regulatory developments and ensure good practice.

Consent

By using our website, you consent to our Privacy Policy and agree to its terms.

Information we collect

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

When you register for an account, we may ask for your contact information, including items such as name, company name, phone number, address, and email address.

Log Files

ELT Consultants ©  follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and are a part of hosting services’ analytics. The information collected by log files includes internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users’ movement on the website, and gathering demographic information.

Cookies and Web Beacons

Like any other website, ELT Consultants ©  uses ‘cookies’. These cookies are used to store information including visitors’ preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users’ experience by customizing our web page content based on visitors’ browser type and/or other information.

For more general information on cookies, please read “What Are Cookies”.

These cookies have an expiration date. If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser. When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

About our cookie policy

Our Cookie Policy explains what cookies are and how we use them. You should read this policy to understand what cookies are, how we use them, the types of cookies we use i.e, the information we collect using cookies and how that information is used, and how to control the cookie preferences. For further information on how we use, store, and keep your personal data secure, see our Privacy Policy on this page. You can at any time change or withdraw your consent from the Cookie Declaration on our website.
Your consent applies to the following domains: https://www.elt-consultants.com/

Your current state: No consent given. Manage your consent.

What are cookies?

Cookies are small text files that are used to store small pieces of information. The cookies are stored on your device when the website is loaded on your browser. These cookies help me make the website function properly, make the website more secure, provide a better user experience, understand how the website performs, and analyze what works and where it needs improvement.

How do we use cookies?

Like most online services, our website uses cookies first-party and third-party cookies for a number of purposes. First-party cookies are mostly necessary for the website to function the right way, and they do not collect any of your personally identifiable data. The third-party cookies used on our websites are used mainly for understanding how the website performs, how you interact with our website, keeping our services secure, and all in all providing you with a better and improved user experience and help speed up your future interactions with our website.

What types of cookies do we use?

Essential: Some cookies are essential for you to be able to experience the full functionality of our website. They allow me to maintain user sessions and prevent any security threats. They do not collect or store any personal information. For example, these cookies allow you to log-in to your account and add products to your basket, and checkout securely.

Statistics: These cookies store information like the number of visitors to the website, the number of unique visitors, which pages of the website have been visited, the source of the visit, etc. These data help me understand and analyze how well the website performs and where it needs improvement.

Functional: These are the cookies that help certain non-essential functionalities on our website. These functionalities include embedding content like videos or sharing content on the website on social media platforms.

Preferences: These cookies help me store your settings and browsing preferences like language preferences so that you have a better and more efficient experience on future visits to the website.

How can you control the cookie preferences?

Should you decide to change your preferences later through your browsing session, you can click on the “Privacy & Cookie Policy” tab on your screen. This will display the consent notice again enabling you to change your preferences or withdraw your consent entirely. In addition to this, different browsers provide different methods to block and delete cookies used by websites. You can change the settings of your browser to block/delete the cookies. To find out more on how to manage and delete cookies, visit www.allaboutcookies.org.

Comments

If you leave a comment on our site you may opt-in to saving your name, email address, and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

How we use your information

I use the information we collect in various ways, including to:

• Provide, operate, and maintain our websites
• Improve, personalize, and expand our websites
• Understand and analyze how you use our websites
• Develop new products, services, features, and functionality
• Communicate with you, provide you with updates and other information relating to our websites, and for marketing and promotional purposes
• Send you emails
• Find and prevent fraud

How is your data shared?

Visitor comments may be checked through an automated spam detection service. Your data is not shared with anyone outside of our website except the plugins installed on the websites required to complete analysis.

How do we protect your data?

Your information is encrypted and ELT Consultants cannot see it. We use an SSL certificate so that all of your information is safely stored.

How long do we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our websites (if any), we also store the personal information they provide in their user profiles. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

CCPA Privacy Rights (Do Not Sell My Personal Information):

Under the CCPA, among other rights, all visitors have the right to:

• Request that a website that collects visitors’ personal data disclose the categories and specific pieces of personal data that a website has collected about visitors.
• Request that a website deletes any personal data about the visitor that a website has collected.
• Request that a website that sells a visitor’s personal data, not sell the visitors’ personal data
• If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
• This does not include any data we are obliged to keep for administrative, legal, or security purposes.

GDPR Data Protection Rights

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

• The right to access – You have the right to request copies of your personal data.
• The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
• The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
• The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
• The right to object to processing – You have the right to object to the processing of your personal data, under certain conditions.
• The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
• If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
• This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Children’s information

ELT Consultants does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best to promptly remove such information from our records.

Strategy for Data Protection

As Companies demonstrating strong compliance with the GDPR and its relationship to the Data Protection Act of 2018, we take data collection, retention, and removal very seriously. For more information on our general privacy policy and data collection practices, please see https://www.elt-consultants.com/legal-pages/ and the Data Protection Officer for this project – Wendy Arnold – can be contacted at [email protected]

Apart from GDPR and Data Protection Act compliance, we are familiar with working in environments where other practices may be more commonplace, or lawful requirements. We aim to maintain our data practices outlined below, whilst recognising that local factors may be brought to bear on any individual project.

Data Collection
Data collection for this project will be carried out by authorised staff, using a variety of tools and devices, including secure online forms and other collection tools. Our staff will only collect the data needed, as agreed with the British Council. When data collection is carried out, participants will be made fully aware of what data is being collected, how it will be stored and used, and what measures are in place for its automatic removal, or for its removal on request (where such a request is in line with GDPR regulations and the project aims). Where physical data collection involving hard-copy matter is necessary, paper-based data will be input and transferred to digital storage as soon as feasibly possible, and hard copies destroyed where appropriate. All digital collection is carried out using secure online tools and sites.

Data Storage
Once collected, data will be transferred to secure storage online, and access limited only to those working on the project, and then on a more granular level at the team-level within the project. This level of redundancy ensures that data is both available to project staff, but also safe, secure and easily recoverable in the case of any storage failure at any given node in the process. Data storage is limited not only by agreements set at the time of the data collection, but also by GDPR rules regarding data retention. For projects of a sensitive nature, we are able to offer encrypted data storage and sharing.

Data Sharing
Data sharing will only be carried out upon agreed lines with the British Council, and with company staff on a role-by-role basis. ELT Consultants staff and consultants will only be given access to the data that they need to successfully carry out any given part of a project. This access will normally be via secure online services, but may also be in the form of physical media such as a secure USB drive or similar, as required. Data is never transferred using unsecured or non-encrypted means.

Data Removal
Once the project has successfully finished – and with the agreement of the British Council – all stored copies of the data will, where appropriate, be deleted from both the online and local storage facilities. If this is not carried out as standard, ELT Consultants will apply workable GDPR practices to ensure that data is deleted at an appropriate juncture and point in time.

Data Breaches
Data breaches, should they happen, are reported in the first instance to the Data Protection Officer (see above) who will take any and all appropriate steps to minimise the potential damage of such a breach, and to inform involved parties so that they make take similar actions as appropriate.

Anti-Corruption, Anti–Collusion and Tax Evasion

1.1          The Supplier undertakes and warrants that it and any Relevant Person has not offered, given or agreed to give (and that it and any Relevant Person will not offer, give or agree to give) to any person any gift or consideration of any kind as an inducement or reward for doing or forbearing to do anything in relation to the obtaining of this Agreement or the performance by the Supplier of its obligations under this Agreement.

1.2          The Supplier acknowledges and agrees that British Council may, at any point during the term of this Agreement and on any number of occasions, carry out searches of relevant third-party screening databases (each a “Screening Database”) to ensure that neither the Supplier, any Relevant Person, nor the Supplier’s and any Relevant Person’s directors or shareholders (where applicable) are listed as being a politically exposed person, disqualified from being a company director, involved with terrorism, financial or other crime, subject to regulatory action or export, trade or procurement controls or otherwise representing a heightened risk of involvement in illegal activity (together, the “Prohibited Entities”).

1.3          The Supplier warrants:

1.3.1              that it, and any Relevant Person, will not make payment to, transfer property to, or otherwise have dealings with, any Prohibited Entity;

1.3.2              that it, and any Relevant Person, has and will retain in place, and undertakes that it, and any Relevant Person, will comply with, policies and procedures to avoid the risk of bribery (as set out in the Bribery Act 2010), tax evasion (as set out in the Criminal Finances Act 2017) and fraud within its organisation and in connection with its dealings with other parties, whether in the UK or overseas; and

1.3.3              that it, and any Relevant Person, has not engaged and will not at any time engage, in any activity, practice or conduct which would constitute either:

(i)            a UK tax evasion facilitation offence under section 45(1) of the Criminal Finances Act 2017; or

(ii)           a foreign tax evasion facilitation offence under section 46(1) of the Criminal Finances Act 2017; and

1.3.4              that it, and any Relevant Person, has not colluded, and undertakes that it will not at any time collude, with any third party in any way in connection with this Agreement (including in respect of pricing under this Agreement).

1.3.5              Nothing under this clause 11.3 is intended to prevent the Supplier from discussing the terms of this Agreement and the Supplier’s pricing with its professional advisors.

1.4          If the Supplier, or any Relevant Person is listed in a Screening Database for any of the reasons set out in clause 11.2 or breaches any of its obligations set out in clause 11.3, it shall promptly notify the British Council of any such listing(s) or breach(es) and the British Council shall be entitled to takes the steps set out at clause 11.5 below.

1.5          In the circumstances described at clause 11.3, and without prejudice to any other rights or remedies which the British Council may have, the British Council may:

1.5.1              terminate this Agreement without liability to the Supplier immediately on giving notice to the Supplier; and/or

1.5.2              require the Supplier to take any steps the British Council reasonably considers necessary to manage the risk to the British Council of contracting with the Supplier (and the Supplier shall take all such steps and shall if required provide evidence of its compliance); and/or

1.5.3              reduce, withhold or claim a repayment (in full or in part) of the charges payable under this Agreement; and/or

1.5.4              share such information with third parties.

1.6          The Supplier shall provide the British Council with all information reasonably requested by the British Council to complete the screening searches described in clause 11.2.

1.7          Without limitation to clauses 11.1, 11.2, 11.3, 11.4, 11.5, and 11.6 above, the Supplier shall ensure that all Relevant Persons involved in providing the Services or otherwise in connection with this Agreement have been vetted and that due diligence is undertaken on a regular continuing basis to such standard or level of assurance as is reasonably necessary for relation to a person in that position in the relevant circumstances.

1.8          For the purposes of this clause 11, the expression “Relevant Person” shall mean all or any of the following: (a) Relevant Persons, and (b) any Relevant Person employed or engaged by a Relevant Person. 

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