Mission and Vision

Zorlu Group

Quality Certificates

Vestel UK Limited

Modern Slavery Act Transparency Statement - 2019-2020

1. INTRODUCTION

Modern slavery and human trafficking are completely unacceptable in a modern society and businesses can play a crucial role in tackling this. Vestel UK Limited takes this very seriously, is fully committed to ensuring that its business and supply chain are free from slavery and human trafficking and takes a zero-tolerance approach.

Section 54 of the Modern Slavery Act 2015 ("MSA") places a legal requirement on large businesses such as Vestel UK Limited to publish an annual statement of the steps that the organisation has taken during the previous financial year to ensure that modern slavery (including human trafficking) is not taking place in its business or supply chain. This statement is made pursuant to the MSA for the financial years ending 31 December 2019 and 31 December 2020 where we have taken steps to identify and reduce the risks of slavery and human trafficking taking place in our supply chain and business.

2. ORGANISATIONAL STRUCTURE AND SUPPLY CHAINS

2.1 Our organisation

Vestel UK Limited is a reseller of electrical goods, including televisions, domestic appliances (such as refrigerators and washing machines), cooking appliances, professional displays and electric vehicle chargers, in the durable consumer and business to business goods sectors. It operates from one main location, Vestel House, 1 Waterside Drive, Langley, Berkshire, England SL3 6EZ and has an annual worldwide turnover of over £280,000,000 (FY 2020).

2.2 Our Parent Company

Vestel UK Limited is part of the Vestel Group of Companies (the "Group") and our parent company is Vestel Ticaret A.S., which has its head office in Turkey. The Group has over 16,000 employees worldwide; its international sales and marketing organisation comprises 11 local sales offices, of which 10 are located in Europe, generating a worldwide turnover of $3,028,000,000 in 2019 and exporting to 156 countries. We procure all the goods we sell from our parent company. Zorlu Holding is the parent company of Vestel Group of Companies.

Employees

The Group is aware that the underlying factors for sustainable success heavily depend on highly motivated and happy employees who have the skills to utilise in pursuit of a common goal. The Group continually reinforces its existing workforce by investing in qualified human resource. The Group is aware that a qualified workforce is the most important factor for providing quality customer service in addition to maintaining and improving its technological superiority and leadership in design. Accordingly, the Group manages its human resources through detailed procedures which include all legal and regulatory requirements, including the Modern Slavery Act.

The Human Resources Policy is available in the Corporate Governance / Human Resources Policy section. The following statement is specifically mentioned in all regulations: “No discrimination is permitted in applications on the basis of gender, age, religion, race, sect, social status, physical appearance, ethnic origin, nationality, sexual orientation or any other personal characteristics.”

In recruitment practices, equal opportunity is provided to all individuals and a fair and unbiased evaluation is taken as a basis. In line with the sustainability goals for 2022 set out by Zorlu Holding, which covers all the Zorlu Group companies, projects have been initiated providing equal opportunities to employees in recruitment, promotion and support practices.

The Group Human Resources team continue to receive recognition at international human resources organisations and won the Silver Award at Brandon Hall Human Resources Excellence Awards.

Within the scope of its 2019 program, Vestel Technology Academy continued to provide post-graduate level training. The Vestel Technology Academy won the Golden Award in the competition organized by TEGEP in Turkey in 2018. In the international arena, the Academy won the Bronze Award in the category of “Human Resources Team of the Year” at the Stevie International Business Awards.

Occupational Health and Safety Policies and Practices

Vestel is highly sensitive about occupational health and safety for the work environment, attaching priority on the assessment and management of the potential impact of risks in the workplace to personnel, subcontractors, visitors, solution partners and other employees.

Work to establish the ISO 45001 Occupational Health and Safety Management System is continuing. The certification process is planned to be completed in 2020.

Vestel continually trains its personnel to ensure that they adopt the right behavioural patterns with respect to quality, environmental awareness, energy efficiency, information security and potential health and safety risks. The framework of Vestel’s Occupational Health and Safety Policies comprises the following:

• To create a “Safety Culture” throughout the Company and ensure that it is adopted,
• To protect from dangerous and health-hazardous conditions that may occur during activities and to create a healthier work environment by conducting up-to-date risk analyses based on the policy of “preventing before it happens”,
• To ensure occupational health and safety together with employees by asking for their feedback through constant training and platforms which support employee engagement,
• To consider occupational health and safety as an indispensable priority for all employees and as an inseparable part of their work,
• To create a safe working environment by fully preventing or minimizing fire risk and accidents in operations,
• To eliminate or minimize unsafe situations and unsafe acts in the workplace by conducting risk analyses and by implementing preventive plans in line with the principle of “The right work for the right employee”.

In line with the Company’s Occupational Health and Safety Policy, all necessary work is carried out to achieve the target of zero accident and occupational illness. Furthermore, compulsory training programmes on occupational health and safety are provided to all Zorlu Holding employees in accordance with all relevant regulations.

Suppliers

Zorlu Holding considers the compliance of all suppliers with environmental, social and ethical standards and principles as critical. e-training on ethical principles was set up on the Zorlu Academy online training platform in order to ensure that Zorlu Holding’s Code of Ethics, which was prepared in 2018 to cover all the Group companies within Zorlu Holding, are adopted by all employees, including Vestel Group employees. The training aims to increase employees’ awareness of Zorlu Holding’s Code of Ethics and to guide how to instil a way of working in line with these principles. The Code of Ethics training was prepared within the scope of the Corporate Governance Working Group activities carried out under the umbrella of Smart Life 2030, under the coordination of the Audit General Directorate and the Human Resources Group Presidency. The online training platform was rolled out in Zorlu Holding in March 2019 and was implemented within the Vestel Group of Companies in July 2019 with the Code of Ethics training provided to all employees through the online system.

Vestel is a signatory of the “Zorlu Holding Supplier Code of Conduct”, comprising supply principles with its suppliers, prepared as part of the group sustainability efforts. With these principles, the company’s suppliers agree to comply with the conditions set out under the main headings such as Discrimination Prevention, Humanitarian Treatment, Remuneration, Working Hours, Occupational Health and Safety, the Environment and Ethics. Regular audits for compliance of these principles are conducted with the biggest suppliers.

ZORLU HOLDING SUPPLIER CODE OF CONDUCT

Sustainability

Vestel manages its sustainability strategy with targets in line with the “Smart Life 2030” sustainability policy adopted by Zorlu Holding and Zorlu Group companies, which is based on the United Nations Sustainable Development Goals for 2030.

Smart Life 2030 aims to provide concrete long-term and measurable solutions to global economic, environmental and social problems. The Company places sustainability at the heart of its growth and common value creation process, in line with its business strategy, which is focused on technology and the development of innovative solutions, taking care of all stakeholders within the sphere of influence of Zorlu Group.

Within the framework of Zorlu Group’s Smart Life 2030 sustainability approach, key focus areas in the field of sustainability were identified in line with the Sustainable Development Goals set out by the United Nations to eliminate poverty, protect the world and ensure that all people live in peace and prosperity, and efforts are carried out to achieve these goals. Within this framework, “a zero-injury severity rate” is one of the five main indicators.

Zorlu Holding is a member of the UNGC (United Nations Global Compact). Vestel Group companies have also applied to become members of UNGC. All Group companies are committed to comply with all ten principles listed on the UNGC website, of which the first two are directly linked to human rights.

https://www.unglobalcompact.org/what-is-gc/mission/principles

Two Vestel Group companies listed on the Istanbul Stock Exchange (BIST) are included in the BIST Sustainability Index since 2015, placing sustainability firmly across their entire business model, from the use of technology to management strategies. Having been listed in the BIST Sustainability Index for four years, Vestel companies are qualified for inclusion in the index for a fifth year with effect from November 1, 2019, thanks to continued compliance with the index criteria.

The “Viva!” Project, which first emerged as an employer branding project, was approved as a sustainability project in 2019. The project focuses primarily on “Corporate Good Life (Well-being),” which is a priority among sustainability goals, and aims at ensuring the sustainability of both the quality of life of the employees and corporate longevity. The Viva! project is planned to be implemented throughout Vestel in 2020.

The Group’s Code of Ethics can be accessed at the following website:

http://www.vestelinvestorrelations.com/en/corporate-governance/code-of-ethics.aspx

2.3 Our Supply Chains

Vestel UK Limited understands the importance of transparency in its supply chain and endeavours to ensure that its suppliers do not engage in any abusive, exploitative or illegal activities. We expect all of our suppliers to be fully committed to our zero-tolerance approach to modern slavery and human trafficking.

Our parent company, Vestel Ticaret A.S., supplies us with the goods we sell, the large majority of which are manufactured by Vestel Ticaret A.S. in Turkey, the remainder being imported on our behalf by Vestel Ticaret A.S. from Thailand and China. In total, we procure goods and services from around 350 suppliers based in 18 countries. The goods and services we procure include those relating to advertising, marketing, translation, website hosting, legal, professional, audit, consultancy, distribution, packaging, repairs, cleaning, site maintenance, security, catering and others.

We also outsource services including our payroll, office cleaning, after sales call centres and repair facilities to a handful of providers in the UK and EU countries.

We store and distribute our goods through third-party warehouses. A forwarding company based in the UK arranges on our behalf customs clearance and goods despatch.

2.4 Our Employees

All Vestel UK Limited’s employees are subject to our Code of Conduct which details our relevant policies. In particularly, our recruitment policy reflects the zero-tolerance approach that we have towards modern slavery, with similar dedication expected from our recruitment partners too.

Vestel UK Limited forbids abuse and discrimination in its workforce and ensures that we comply with all applicable laws and regulations. We conduct relevant checks at each recruitment stage to prevent slavery and human trafficking. We ensure that universal employment principles, such as equal opportunity to all employees, regardless of their nationality, race, gender, religion, sexual orientation or physical disabilities, are fully respected.

3. OUR POLICIES

As part of Vestel UK Limited's commitment to ensuring that our business and supply chain are slavery-free, we are implementing a Modern Slavery Policy and a Supplier Code of Conduct. Everyone who works for Vestel UK Limited will be obliged to comply with the Modern Slavery Policy. All our first-tier suppliers will be required to accept contractual obligations to comply with our Supplier Code of Conduct and to oblige suppliers who supply them with goods/services to do so as well.

4. RISK MONITORING AND COMPLIANCE

As part of our initiative to identify and address risks of slavery in our supply chain we:

• Review relationships with our suppliers periodically.
• Only engage workers from reputable employment agencies and professional bodies and always undertake identification and other checks (passport, eligibility to work and former employment reference checks) before accepting a worker.
• Visit Vestel Group manufacturing facilities with our customers periodically for general inspection and audit.

MATTHEW LANG

MANAGING DIRECTOR, VESTEL UK LIMITED

Vestel UK Limited

PRIVACY NOTICE

Vestel UK Limited ("Vestel UK") commits to using any personal data you give us responsibly and in accordance with all applicable laws and data privacy regulation. This Privacy Notice explains the types of personal information we collect, how we use that information, who we share it with, and how we protect that information.

Please read the following carefully to understand our views and practices regarding your personal data, and how we will treat it.

1. Who we are

For the purposes of applicable data protection laws, the data controller is Vestel UK Limited of Waterside Langley Slough Berkshire SL3 6EZ, registered number 04771550. Please see below for our contact details.

2. Information covered by this Privacy Notice

This Privacy Notice covers all personal data collected and used by Vestel UK. "Personal data" or "personal information" means information that (either in isolation or in combination with other information held by us) enables you to be identified as an individual or recognised directly or indirectly. This includes the types of information set out below.

3. What information do we collect from you?

We may collect information about you from the following sources:

1. Information we receive from you

We may collect personal information (your name, postal and email address, telephone number, purchase information, organisation and job title, passport details-only for conferences or trade fairs) that you provide to us when you:

• order products on Finlux, eBay and Amazon;
• contact us to obtain warranty service or request repair of faulty goods;
• engage with our social media to take part in competitions;
• contact us about sales as a customer organisation;
• contact us about reviewing our products or attendance at a conference or trade fair; and
• otherwise provide us personal information.

2. Information we get from your use of our website and services

Like most organisations, we collect technical information about the services you use and how you use them (such as your browser type and version, IP address, operating system, platform and your location) for instance when you:

• visit our websites;
• view and interact with our digital advertising and website or social media content.

This information may be used to improve the services we offer.

To learn more about how we use cookies and how to control which cookies are used, please see our Cookie Policy below.

3.Information we get from other sources

We may collect the personal information of influencers, reviewers and journalists (such as name, address, email and phone number) from a specialised online network.

4. How do we use your personal information?

5. Children's privacy

We will never knowingly collect personal information from individuals under the age of thirteen (13) without first obtaining verifiable parental consent. If you are under the age of 13, you should not provide information to us. If we become aware that a person under 13 has provided personal information to us without verifiable parental consent, we will remove such personal information from our files.

6. Sharing your data with third parties

Your personal information are intended for Vestel UK, and may be shared with third parties in certain circumstances.

Our website may, from time to time, contain links to and from the websites of our partners or affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we have no control over how they may use your personal information. You should check the privacy policies of third party websites before you submit any personal information to them.

We may share your personal information with the following third party organisations:

• Vestel UK's group of companies

  We may share your personal information among our group of companies, including our subsidiaries in order to administer our services and products, provide you with customer support in relation to your complaints, process your orders, understand your preferences, send you information about products and services that may be of interest to you, and conduct the other activities described in this Privacy Notice.

• Our service providers

  We use other companies, agents or contractors ("Service Providers") to perform services on our behalf. We may share personal information with the following categories of Service Provider:

  • infrastructure and IT services providers,
  • marketing (including market research), advertising and communications agencies,
  • fulfilment, warehouse, courier/delivery and logistics partners,
  • service repair, call center intermediary,
  • payment processors for online direct sales.

In the course of providing such services, these Service Providers may have access to your personal information. However, we will only provide our Service Providers with the information that is necessary for them to perform the services, and we ask them not to use your information for any other purpose. We will always use our best efforts to ensure that all the Service Providers we work with will keep your personal information secure.

• Our strategic partners, subject to your consent

  Our selected partner organisations may use your personal information, but only with your consent. Such sharing of personal information is for the purposes of improving and providing our products and services to you. Your personal information will not be shared with third parties for their marketing purposes.

• Third parties permitted by law

  In certain circumstances, we may be required to disclose or share your personal information in order to comply with a legal or regulatory obligation (for example, we may be required to disclose personal information to the police, regulators, government agencies or to judicial or administrative authorities).

  We may also disclose your personal information to third parties where disclosure is both legally permissible and necessary to protect or defend our rights, matters of national security, law enforcement, to enforce our Terms and Conditions or protect your rights or those of the public.

• Third parties connected with business transfers

  We may transfer your personal information to third parties in connection with a reorganisation, restructuring, merger, acquisition or transfer of assets, provided that the receiving party agrees to treat your personal information in a manner consistent with this Privacy Notice.

  We will not sell your personal information to third parties.

7. Where we store your personal information

The personal information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") (for example, our parent company in Turkey). It may also be processed by staff operating outside the EEA who work for us or for one of our Service Providers.

We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Notice and applicable data protection laws, including, where relevant, entering into EU standard contractual clauses (or equivalent measures) with the party outside the EEA receiving the personal information.

8. Your rights

If you are in the European Economic Area, you have the right to:

• Access. You have the right to request a copy of the personal information we are processing about you, which we will provide back to you in electronic form. For your own privacy and security, in our discretion we may require you to prove your identity before providing the requested information. If you require multiple copies of your personal data, we may charge a reasonable administration fee.

• Rectification. You have the right to have incomplete or inaccurate personal information that we process about you rectified.

• Deletion. You have the right to request that we delete personal information that we process about you, except we are not obligated to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.

• Restriction. You have the right to restrict our processing of your personal information where you believe such data to be inaccurate, our processing is unlawful or that we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.

• Portability. You have the right to obtain personal information we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (a) personal information which you have provided to us, and (b) if we are processing that data on the basis of your consent or to perform a contract with you (such as to deliver your orders).

• Objection. Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.

• Withdrawing Consent. If you have consented to our processing of your personal information, you have the right to withdraw your consent at any time, free of charge. This includes cases where you wish to opt out from or change your preferences in relation to marketing messages that you receive from us.

You can make any of these requests in relation to your personal data by sending the request by mail to Compliance Department, Vestel UK Limited Waterside Langley Slough Berkshire SL3 6EZ or email to Gdpr_info@vestel-uk.com

You also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws.

If you are based in, or the issue relates to, the UK, the Information Commissioner’s Office can be contacted as follows:

Telephone: +44 0303 123 1113
Email: casework@ico.org.uk
Website: www.ico.org.uk
Web-form: www.ico.org.uk/concerns/
Address: Water Lane, Wycliffe House, Wilmslow, Cheshire, SK9 5AF

9. How long do we keep your personal information?

We will only retain your personal data to the extent necessary for the performance of our obligations, and for the time necessary to achieve the purposes for which that data was collected, in accordance with applicable laws. When we no longer need to use your information, we will remove it from our systems and records and/or take steps to properly anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).

Cookies

Vestel UK website uses cookies, which are small text files on your device (computer, smartphone etc.). They are made by your web browser when you visit a website. Every time you go back to that website, your browser will send the cookie file back to the website's server. They improve your experience of using a website, for example, by remembering your preference settings and by measuring your use of a website to ensure that it meets your needs. Cookies can also be used to show you relevant Vestel UK content on social media services such as Facebook - these are known as 'retargeting' or 'advertising' cookies.

For further information about cookies, including to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or https://www.allaboutcookies.org.

You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.

Changes to this Privacy Notice

This Privacy Notice is written in English and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this notice, the English version shall prevail.

We reserve the right to change our Privacy Notice from time to time. If we decide to change our Privacy Notice we will post an alert on the home page of our global website.

Issue date: 25 May 2018

Vestel UK Limited

Vestel Holland BV UK Branch Office

2021 Tax Strategy

Vestel UK Limited and Vestel Holland BV are two of 18 subsidiaries of Vestel Group, the parent company in Turkey. 

The principal activity of Vestel UK Limited and Vestel Holland BV UK Branch Office is to market, promote, service and distribute branded products to the Consumer Electronics and Major Domestic Appliances marketplaces within the UK and Europe. Brands include Sharp and Toshiba, sold under licensing agreements, as well as those of Vestel Group and retailers.

In compliance with paragraphs 19 and 25 of Schedule 19 to the Finance Act 2016, the company is publishing its tax strategy for the year ending 31 December 2021.

Our Tax Strategy 

Vestel UK Limited and Vestel Holland BV UK Branch Office are committed to complying with UK tax legislation and have identified risk areas in Corporation Tax, PAYE, NIC and VAT. Responsible persons have been appointed to these areas of Tax compliance.Regular meetings are held to review new compliance and ensure knowledge is up to date. Systems, controls and processes are monitored to aid the policing of this area.

Risk management & governance arrangement 

Risk management isa critical element of Vestel companies’ everyday business activities and takes place at all levels of our organisation. 

Vestel UK and Vestel Holland BV UK Branch Office are committed to compliance with tax law and practice in the UK. Compliance for us means paying the right amount of tax in the right place at the right time. 

Vestel UK Limited and Vestel Holland BV UK Branch Office seek assistance from external professionals and tax specialists to mitigate risks. 

• We have a monthly compliance review to check due dates for payment and filing deadlines. 

• We have developed a system to capture relevant financial data accurately to mitigate any risk. 

• We educate staff on issues of compliance and try to adhere to tax legislations on a prompt basis. 

• We seek help from external professionals in specialist tax areas and have timely communication with them to resolve any unclear issues. 

• We take immediate remedial actions when we find any errors/mistakes and have a control system is in place to prevent further occurrences. 

• We encourage staff to draw attention to any issues/uncertainties and take the relevant measurements to resolve the issues. 

• We proactively plan our workloads in order to perform on a timely basis reducing the risk of mistakes/errors, which will add value to all stakeholders.

Attitude towards tax planning and level of risk 

We manage risks to ensure compliance with legal requirements in a manner which ensures payment of the right amount of tax. 

Our attitude towards tax planning is to be aligned with our business strategy and disclose relevant facts to relevant tax authorities. 

We will not put in place any arrangements that are contrived or artificial where the sole purpose of which is to reduce UK tax. 

Relationship  with HMRC 

Vestel UK Limited and Vestel Holland BV UK Branch Office seek to ensure that our engagement with HMRC is proactive, transparent, open and honest and is conducted in a co-operative manner. We aim to communicate promptly with HMRC by responding/taking actions or seeking advice either directly or via agents. We would seek to contact HMRC for any clearance issues in a timely and professional manner.

Terms & Conditions of Trade

View Terms & Conditions of Trade document.