The following terms and conditions apply to this site. Henley Homes may vary these terms from time to time and the revised terms will be deemed to apply at the relevant time in respect of your registration. No other terms shall apply. By proceeding to use the site, you agree to be bound by the following conditions.
Henley Homes plc understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.henley-homes.co.uk and We do not collect personal data about you unless you contact Us. Any personal data We do collect will only be used as permitted by law.
Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our” means Henley Homes plc, a limited company registered in England under company number 3718331, whose registered address is 50 Havelock Terrace, London SW8 4AL
What Does This Policy Cover?
As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided under the ‘How Can You Access Your Data’ section and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
What Data Do We Collect?
If you register on this site, you will be asked to provide certain information about yourself (such as your name, address, email address and telephone number). We only ask that this information is provided should you want to make an inquiry or speak to us about our products or services. We only collect the minimum data required to carry out your inquiry.
We may also collect some technical data such as your Internet Protocol (IP) address which connects your computer or mobile device to the internet, your login information, browser type and version. This is necessary for Us to allow you to use Our Site.
How Do We Use Your Data?
If We do collect any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times.
If you contact Us and We obtain your personal details from your email or by registering on Our Site, We may use them as follows:
You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it. We provide an unsubscribe option on all of our communications.
If we do process your personal data, we may use one or more of the following lawful basis for processing:
Consent: We may Process your Personal Data where we have obtained your prior, express consent to the Processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way);
Contractual: We may Process your Personal Data where the processing is necessary in connection with any contract that you may enter into with us;
Compliance with applicable law: We may Process your Personal Data where the processing is required by applicable law;
Vital interests: We may Process your Personal Data where the processing is necessary to protect the vital interests of any individual; or
Legitimate interests: We may process your Personal Data where we have a legitimate interest in carrying out the processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.
How Long Do We Keep Your Data?
Henley Homes plc shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed.
We will always retain your personal information in accordance with law and regulation and never retain your information for longer than is necessary.
When personal data is no longer required, all reasonable steps will be taken to securely erase or otherwise dispose of it without delay.
Where Do We Store Your Data?
Your data will only be stored in the UK in our Data Centre which is supplied and maintained by our IT provider
Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure any data We hold about you (even if it is only your email address).
How Can You Access Your Data? (Subject Access Request)
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge.
We may require proof of your identity before we can give effect to these rights.
Please contact Us for more details at email@example.com or by telephone on +44 (0)20 7401 8777
Do We Share Your Personal Data?
To fulfil certain services, we work with some external suppliers and organisations such as Agents, Solicitors, Consultants and or Local Authorities. For us to provide this order/ service we may need to share your data with one or more of these organisations. We will only share if:
We do not subscribe you to marketing emails without your consent.
We do not sell or give away your contact information to any other entities.
We do not allow the vendors who help us process transactions to sell or give away your information
Links to Other Websites
Last reviewed: March 2021, Rev.2
At the Henley Homes Group, we recognise that slavery and human trafficking are significant human rights issues and we are committed to adherence to the Modern Slavery Act 2015 and are taking appropriate and proportionate steps to mitigate the risk of these occurring within our business and our supply chain.
We have agreed management responsibility for this policy and statement and have received unanimous endorsement from our Key Principals and our Board.
As a property developer and contractor operating within the UK, the key areas of our operation that could be affected by slavery and human trafficking are our directly hired employees, agency workers working on our behalf, contractors, subcontractor operatives working on our sites, and the workforce of our supply chain who supply materials to our business.
The steps that we take to mitigate risks in relation to each of these areas are as follows:
Contractors and Subcontractors
Signed: Tariq Usmani, CEO
Reviewed: 16 December 2020, for the year to December 2021
In the light of Criminal Finances Act 2017, the Company has adopted a ‘Tackling Tax Evasion Statement’ (‘’the statement’’) of our commitment to preventing persons associated with the Company and its subsidiary Companies from engaging in the criminal facilitation of tax evasion in the UK or in a foreign country. This statement will be published on the company’s website and reviewed annually.
The Company is committed to preventing the facilitation of tax evasion by associated individuals or businesses (‘Associated Person’) anywhere within its operations. The statement governs all our business dealings and the conduct of all persons or organisations who are appointed to act on our behalf. All members of staff and all who have, or seek to have, a business relationship with the Company and/or any of its subsidiary companies must familiarise themselves with this Policy and the statement and are required to act at all times in a way which is consistent with the Policy and the statement.
We conduct all our business in an honest and ethical manner. We take a zero-tolerance approach to facilitating tax evasion, whether under UK law or under the law of any foreign country.
We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate; and to implementing and enforcing effective systems to counter tax evasion facilitation.
We will uphold all laws relevant to countering tax evasion, including the Criminal Finances Act 2017, in all the jurisdictions in which we operate.
2. Purpose and Scope of Document
The purpose of this policy is to:
As an employer, if we fail to prevent our employees, workers, agents or service providers facilitating tax evasion, we can face criminal sanctions including an unlimited fine, as well as exclusion from tendering for public contracts and damage to our reputation. We therefore take our legal responsibilities seriously.
All employees within our Company and other relevant third parties are required to be made aware of this policy and demonstrating their understanding of it.
In this policy, third party means any individual or organisation with whom the Company works, and includes, suppliers, customers, casual workers, agency staff, contractors and agents.
3. Personnel Responsible for the Policy
The Company’s Chief Financial Officer has overall responsibility for this Policy and for reviewing the effectiveness of actions taken in response to concerns raised under this Policy.
The Group Commercial Director has day-to-day operational responsibility for this Policy.
4. Who must comply with this Policy?
This policy applies to all persons working for the Company or any subsidiary company or overseas office or on our behalf in any capacity, including employees, casual workers, agency staff, contractors and third parties.
5. What is the Facilitation of Tax Evasion?
For the purposes of this policy:
Under the Criminal Finances Act 2017, a separate criminal offence is automatically committed by an organisation where the tax evasion is facilitated by a person acting in the capacity of an Associated Person to that body. For the offence to be made out, the associated person must deliberately and dishonestly take action to facilitate the tax evasion by the taxpayer. If the associated person accidentally, ignorantly, or negligently facilitates the tax evasion, then the corporate offence will not have been committed. The Company does not have to have deliberately or dishonestly facilitated the tax evasion itself; the fact that the associated person has done so creates the liability for the company.
Tax evasion is not the same as tax avoidance or tax planning. Tax evasion involves deliberate and dishonest conduct. Tax avoidance is not illegal and involves taking steps, within the law, to minimise tax payable (or maximise tax reliefs).
Tax means all forms of UK taxation, including but not limited to corporation tax, income tax, value added tax, stamp duty, stamp duty land tax, national insurance contributions (and their equivalents in any non-UK jurisdiction) and includes duty and any other form of taxation (however described).
6. What You Must Not Do
It is not acceptable for you (or someone acting on your behalf) to:
7. Your Responsibilities
You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of tax evasion and foreign tax evasion are the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future. For example, if an employee or supplier asks to be paid into an offshore bank account, without good reason, or a supplier asks to be paid in cash, indicating that this will mean the payment is not subject to applicable tax. Further “red flags” that may indicate potential tax evasion are set out in Section 10 below.
8. Training and Communication
Finance & Commercial Development staff will be formally briefed by the Group Commercial Director
Our zero-tolerance approach to tax evasion and foreign tax evasion must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate after that.
9. Breaches of This Policy
Any employee who breaches this policy may face disciplinary action, which may result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
10. Potential Risk Scenarios: “Red Flags”
The following is a list of possible red flags that may arise while you work for the Company and which may raise concerns related to tax evasion or foreign tax evasion. The list is not intended to be exhaustive and is for illustrative purposes only. If you encounter any of these red flags (or other activity likely to fall under this policy) while working for the Company, you must report them promptly to your manager:
11. Associated Policies
The following policies are also available in the company handbook or on the company intranet:
Bribery and Corruption Policy
Corporate Social Responsibility
12. Procedure for Making a Disclosure
Should any member of staff or Associated Person become concerned that a fellow employee or Associated Person is facilitating a third party’s tax evasion they should immediately contact their own Head of Department, the Commercial Director or the Chief Financial Officer.
Approved by directors on 5 July 2021