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Legal and privacy policy

  • Privacy policy
  • Bribery
  • Modern slavery statement
  • UK tax strategy
  • Gender pay gap

Welcome to The Lotus Group t/a DialAFlight and Supertravel's privacy notice.

The Lotus Group respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or when you otherwise provide personal data to us via other means (such as over the telephone) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so that you can easily click through to the specific areas set out below.

Please also use refer to the Glossary that we have set out at the end of the Policy, if there is any terminology used in this privacy notice that you are unfamiliar with or that you don’t fully understand.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Lotus collects and processes your personal data, including any data you may provide through this website or via any other means (such as over the telephone) when you request a quote from us, when you purchase travel services, when you sign up to our newsletter, when you take part in a competition etc.

This website is not intended for children and the only circumstances in which we collect data relating to children, is where you make a booking of travel services and you have children in your party.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

The Lotus Group is made up of different legal entities, as follows:

(a) Lotus Travel Limited;

(b) Lotus International Limited; and

(c) Lotus Leisure Limited.

This privacy notice is issued on behalf of the Lotus Group so when we mention "Lotus", "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the Lotus Group responsible for processing your data. We will let you know which entity your are dealing and contracting with when you purchase a product or service with us.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights , please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Lotus Group Limited, Lotus Travel Limited, Lotus International Limited and Lotus Leisure Limited.
Name or title of data privacy manager: Karen Hart
Email address: Privacy@lotusgroup.co.uk
Postal address: The Lotus Group, Sandpiper House, 37-39 Queen Elizabeth Street, London, SE12BT
Telephone number: 0207 459 3762

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 24/05/2018 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change, during the course of your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

(A) Identity Data

This includes data relating specifically to your identity, such as your first name, maiden name, last name, marital status, title, date of birth, gender and, in certain circumstances, passport information.

(B) Contact Data

This includes data relating to how you may be contacted, such as your billing address, delivery address, email address and telephone numbers.

(C) Financial Data

This includes data relating to your means and methods of payment, such as your bank account and payment card details.

(D) Transaction Data

This includes data relating to the transactions you have carried out with us, such as details about payments to and from you and other details of products and services you have purchased from us.

(E) Technical Data

This includes more technical data that we may obtain when you make use of our website, such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

(F) Usage Data

This includes information about how you use our website, products and services.

(G) Marketing and Communications Data

This includes your preferences in relation to whether or not you want to receive marketing from us and our third parties and also your communication preferences.


We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.

Special Categories of Personal Data

We collect the following special categories of personal data about you.

Details about your:

Details about your:

  • dietary requirements which may disclose your religious or philosophical beliefs;
  • health;
  • race or ethnicity;
  • information about your preferences surrounding the travel services that you are enquiring about or booking that may disclose details about your sex life and/or your sexual orientation.

We collect and process the above data only where it is strictly necessary to do so in order to deliver the travel service that you have purchased. Furthermore, we will only collect and process the above special categories of sensitive personal data where you have provided us with your explicit consent to do so.

You are not under any obligation to consent to us processing your sensitive personal data. However, without your consent, we won’t be able to make the necessary arrangements to provide the travel services that you have booked or are attempting to book. As a result, if you do not provide your consent, we will be unable to proceed with your booking.

If you are happy to consent to our use of your sensitive personal data, you will also be able to withdraw your consent at any time. However, as this will prevent us or (where we are acting as an agent) the supplier of your chosen travel service from providing the travel service you have booked, we will be required to treat any withdrawal of consent as a cancellation of your booking and the cancellation charges referred to in our Booking Terms and Conditions will become payable.

If you fail to provide personal data

Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.

Where we are acting as an agent and we need to collect personal data to enter you into a contract with the supplier of your chosen travel arrangements, we may not be able to take steps to enter you into that contract if you fail to provide the data when requested.

In other words, where we require details from you in order to provide you with your chosen travel services, if you do not provide us with the necessary details then we will not be able to provide (or arrange for the provision of) the services you have booked or are attempting to book.

In this case, depending upon when you fail to provide the necessary date, we may either not be able to process your booking or we may have to cancel your booking, in which case we will treat this as a ‘cancellation by you’ in accordance with our Booking Terms and Conditions https://www.dialaflight.com/bookingconditions.aspx. We will notify you if we are unable to process a booking or are required to cancel a booking for this reason.

3. How your personal data is collected

We use different methods to collect data from and about you including through:

(A) Direct interactions

This includes more technical data that we may obtain when you make use of our website, such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • make a booking of travel services;
  • request a quote from us;
  • make an enquiry about our travel services;
  • request us to carry out check-in services on your behalf;
  • subscribe to our newsletter or other publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback

(B) Automated technologies or interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.

We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

(C) Third parties

We may receive personal data about you from various third parties as set out below:

  • Technical Data from the following parties:

(i) analytics providers such as Google based outside the EU.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where we need to take steps to enter you into a contract with the supplier of your chosen travel services, where we are acting in an agency capacity.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal. If there are any circumstances where we do obtain and rely on your consent, you will have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer. (a) Identitiy;
(b) Contact.
Performance of a contract with you or taking steps to enter you into a contract.
To process and deliver your booking including:
(a) Manage payments, fees and charges;
(b) Collect and recover money owed to us.
(a) Identity;
(b) Contact;
(c) Financial;
(d) Transaction;
(e) Marketing and Communications.
(a) Performance of a contract with you or taking steps to enter you into a contract;
(b) Necessary for our legitimate interests (to recover debts due to us).
To provide you with visa application services and process any applications for visas on your behalf, where you have instructed us to do so. (a) Identity;
(b) Contact.
Performance of a contract with you or taking steps to enter you into a contract.
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy;
(b) Asking you to leave a review or take a survey.
(a) Identity;
(b) Contact;
(c) Marketing and Communications.
(a) Performance of a contract with you;
(b) Necessary to comply with a legal obligation;
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
To enable you to partake in a prize draw, competition or complete a survey. (a) Identity;
(b) Contact;
(c) Usage;
(d) Marketing and Communications.
(a) Performance of a contract with you;
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). (a) Identity;
(b) Contact;
(c) Technical.
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise);
(b) Necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Usage
(d) Marketing and Communications
(e) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
Necessary for our legitimate interests (to develop our products/services and grow our business)
For the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure (a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Technical
(f) Usage
(g) Marketing
Necessary for our legitimate interests (protection and assertion of our legal rights, your legal rights and the legal rights of others)
For the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice (a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Technical
Necessary for our legitimate interests (the proper protection of our business against risks)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We have set out below the various ways in which you can exert your choices accordingly.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Lotus group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. How we disclose your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

(A) External Third Parties as set out in the Glossary.

(B) Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. When we transfer your data overseas

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Where you have requested a booking for travel arrangements which are located or otherwise due to be fulfilled outside the EEA, we will have to transfer your personal data to the suppliers fulfilling or providing those travel arrangements outside the EEA in order to make your booking and for those suppliers to be able to provide you with the travel arrangements you have booked. Where we are unable to rely on one of the safeguards outlined below when transferring data to those suppliers outside the EEA, we will rely on the derogation under Article 49 of the GDPR in order to transfer your personal data to countries outside the EEA (as the transfer relates to the performance of a contract for your benefit), and you hereby permit us to do so. You also acknowledge that where your personal data is transferred outside the EEA, controls on data protection may not be as wide as the legal requirements within the EEA.

For all other transfers of data, whenever your personal data is transferred outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:


Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. How we secure your data

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. How long we retain your data for

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

If you book with us we will keep your information for 8 years from your return date of travel (in the case of adults) for tax purposes and in order to enable us to defend any legal claims that you may pursue against us.

In addition, in relation to any children that travel on the booking we will keep your information for 6 years from the date of your 18th birthday in order to enable us to defend any legal claims that you may pursue against us.

If you require any further information regarding our retention periods then you can request the same by contacting us.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

(A) Request access to your personal data.
(B) Request correction of your personal data.
(C) Request erasure of your personal data.
(D) Object to processing of your personal data.
(E) Request restriction of processing your personal data.
(F) Request transfer of your personal data.
(G) Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us via Privacy@lotusgroup.co.uk.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data or to exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

LAWFUL BASIS

  • Legitimate Interest
    means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
  • Performance of Contract
    means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • Comply with a legal or regulatory obligation
    means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

  • External Third Parties
    means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
  • Suppliers of travel services acting as processors based around the world (in the locations in which we offer travel services, on our website) who provide the travel services that make up any booking of travel services that you make.
  • Service Providers such as Amadeus based in the EU and Worldspan based in the USA acting as processors who provide airline booking systems to enable us to book any flights that you request and to also process any online check-in services that you request us to perform for you
  • Where we are providing you with visa application services, Embassies, immigration authorities and other suppliers of visa services acting as processors or joint controllers based in the country in which you are applying for a visa and who provide the visas that we assist you to apply for.
  • Barclays Bank PLC acting as a processor based in the United Kingdom who provide us with merchant services.
  • Service providers acting as processors based in the EU who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

  • Request access
    to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction
    of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure
    of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing
    of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing
    • if you want us to establish the data's accuracy;
    • where our use of the data is unlawful but you do not want us to erase it;
    • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer
    of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time
    where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Lotus Group companies are committed to acting ethically and observing all of the laws of the United Kingdom in relation to bribery, corruption, money laundering, fraud, financing of terrorism or any other financial offences. It also takes a zero tolerance attitude to any customer or supplier which may at any time be found to be, or suspected of, contravening those laws. The Group has a policy of adhering to the local laws of any jurisdiction in which it may do business but, as a minimum benchmark, will consider the laws, practices and social norms of the UK as being the guiding principal.

Responsibility

The board of Directors has overall responsibility for ensuring this policy is observed by all of those under its control. Management at all levels are responsible for ensuring that those reporting to them understand and comply with this policy.

Internal Compliance

All staff must ensure that they have read and understand the policy. The recognition of the various aspects financial impropriety whether on the client or supplier side of the business. It should be clear that any activity which may lead to or to suggest a breach of this policy is to be avoided.

The Group will not use any form of payment, travel arrangement or gift to an employee of a supplier, which contravenes the expressed policy on such gifts of any of that supplier.

The reporting of any concerns regarding any aspect of bribery and corruption which may arise in the course of business should be immediately raised at director level. Staff are encouraged to raise genuine concerns even if they turn out to be mistaken. All protections under our “whistle blowing” policy will apply where concerns have been raised in good faith.

Training on this policy and of the legal and reputational risk our business faces with respect to financial misconduct will be provided as necessary.

Supplier Compliance

Our supplier contracts include conditions, as specified in The Bribery Act of 2010, that they will not be involved in bribery and corruption in any of its forms and will furthermore that they will have a zero tolerance policy towards any of their suppliers or subcontractors who may have such involvement.

Any gifts, payments, hospitality or other incentives from suppliers to staff of the group must be officially and expressly made through the group and must comply with the group policy for such incentives.

Any gifts, payments, hospitality or other incentives to suppliers, or other organisations, by the group must be officially and expressly made to the relevant organisation and must not be offered or promised directly to an employee of the organisation, in order secure an advantage to the detriment of the organisation.

Client Compliance

Any gifts, payments, hospitality or other incentives to offered to employees belonging to a client company or organisation, by the group, must not be offered or promised directly to the employee of the organisation in order secure any advantage which would be to the detriment of the organisation.

The booking staff should be aware of any unusual financial arrangements which may give rise to concerns that fraud, money laundering, corruption or any other aspects of financial misconduct, may be occurring. These should be raised at director level and, if the suspicion is seen to be serious enough, reported to the appropriate legal authorities. Staff should never become complicit, either openly or tacitly, in any arrangement or transaction which may be deemed to suspect for financial irregularity. In particular, but not exclusively, any transaction involving public officials.

It is recognised that the group arranges travel for hundreds of thousands of clients and it is not possible to be aware of the motivation behind such arrangements.

Breaches of Policy

Any employee who knowingly and wilfully breaches this policy will be deemed to have committed serious misconduct and will face disciplinary action which could lead to dismissal for gross misconduct.

If any supplier found to be incontrovertibly in breach of this policy the Group will terminate the relationship until such time as they become compliant. Any gross breach may be reported to the appropriate legal authorities.

The Group warrants that neither it, nor any of its subsidiaries, directors or senior management have ever been involved in any such act which would be deemed criminal under UK law.

Lotus Group companies are committed to acting ethically and observing all of the laws of the United Kingdom in relation to slavery, servitude, human trafficking and forced or compulsory labour, which may come under the heading “modern slavery” and in particular the Modern slavery Act 2015 (The Act). It also takes a zero tolerance attitude to any customer or supplier which may at any time be found to be, or suspected of, contravening those laws. The Group has a policy of adhering to the local laws of any jurisdiction in which it may do business but, as a minimum benchmark, will consider the laws, practices and social norms of the UK as being the guiding principal.

Responsibility

The board of Directors has overall responsibility for ensuring this policy is observed by all of those under its control. Management at all levels are responsible for ensuring that those reporting to them understand and comply with this policy.

Internal Compliance

All staff must ensure that they have read and understand the policy. The recognition of the various aspects of modern slavery should be encouraged at all levels, whether on the client or supplier side of the business. It should be clear that any activity which may lead to or to suggest a breach of this policy is to be avoided.

The reporting of any concerns regarding any aspect of modern slavery which may arise in the course of business should be immediately raised at director level. Staff are encouraged to raise genuine concerns even if they turn out to be mistaken. All protections under our “whistle blowing” policy will apply where concerns have been raised in good faith.

Training on this policy and of the legal and reputational risk our business faces with respect to modern slavery will be provided as necessary.

Supplier Compliance

The group has a zero tolerance policy with any supplier who may be involved if Modern Slavery in any of its forms, or which has suppliers or contractors who may have such involvement.

Our supplier contracts include conditions, as specified in The Act, that they will not be involved in Modern Slavery in any of its forms and will furthermore that they will have a zero tolerance policy towards any of their suppliers or subcontractors who may have such involvement.

As a Travel Agent / Tour Operator with global coverage and many thousands of hotels and other ground product suppliers worldwide, a monitoring of or auditing of suppliers for compliance would not be possible. The Group does however make every effort to ensure that the third parties with which it contracts are of the most responsible and highest standard of integrity in their field.

Client Compliance

The booking staff should be aware of any unusual travel arrangements which may give rise to concerns that trafficking, or other aspects of Modern Slavery, may be occurring. These should be raised at director level and, if the suspicion is seen to be serious enough, reported to the appropriate legal authorities.

Breaches of Policy

Any employee who knowingly and wilfully breaches this policy will be deemed to have committed serious misconduct and will face disciplinary action which could lead to dismissal for gross misconduct.

If any supplier found to be incontrovertibly in breach of this policy the Group will terminate the relationship until such time as they become compliant. Any gross breach may be reported to the appropriate legal authorities.

LOTUS GROUP TAX STRATEGY

This strategy is approved by the board of Lotus Group Ltd and sets out the Group’s policy and approach to conducting its tax affairs and dealing with tax risk. The Group is complying with their duty under Schedule 19 paragraph 16(2) FA2016. This strategy will be periodically reviewed. It is effective for the year ending 31 October 2018 and will remain in effect until amendments are approved by the Board.

Group Tax Policy

The Lotus Group philosophy is that the health of its business is directly related to the health of the society in which it operates and that companies which operate within a society should make their proper contribution to the essential institutions of that society.
Lotus Group is committed to:

  • Complying with all applicable laws rules and regulations relating to its tax activities in any tax jurisdiction in which it may operate.
  • Maintaining an honest open and constructive relationship with tax authorities based on integrity and mutual trust
  • Applying diligence and care in the management of tax risks and ensuring that procedures and governance are appropriate.
  • Ensuring the tax strategy is consistent with Group strategy
  • The group may use legitimate reliefs and incentives in order to mitigate tax but will not knowingly use them in a manner contrary to the explicit intent of the legislation.

Risk Management

Tax risks are assessed on a case by case basis with the aim of arriving at well-reasoned conclusions on how each risk should be managed. Where there is any uncertainty as to how a particular tax law should be applied, expert external advice is consulted. All tax related issues are addressed at director level and significant issues at board level.
When reviewing tax risk and arriving at a decision the following are taken into account.

  • The legal and fiduciary duties of the directors and employees
  • Maintenance of the Group’s corporate reputation.
  • The financial impact on the Group’s results and the management’s duties to the shareholders.
  • The impact on relations with the Tax Authorities.

Tax Planning

The Group firmly believes that it should pay all the of tax legally due in any tax jurisdiction in which it may from time to time operate. It reserves the right to take its commercial needs into consideration but these will not override compliance with all applicable laws and regulations.
The Group’s policy has always been that it will not get involved with artificial, complex or aggressive tax planning strategies. In particular, the commercial logic of any actions will not be overridden for purely tax purposes. It does not make use of any low tax regimes overseas to mitigate tax.
Where internal resources are unclear on tax issues or feel that they do not have the necessary depth of knowledge, expert external advice will be sought.

Dealings with HMRC and Overseas Tax Authorities

The group committed to an open and transparent relationship with tax authorities with particular reference to:

  • Fair accurate and timely returns
  • Collaborative professional and open discussions of tax issues which may arise
  • Resolving any disagreements directly where possible. Where agreement cannot be reached the group will act in line with the appropriate legislation and apparent intent of parliament when drafting that legislation

The average woman in this company is paid 26.5% less than the average man. We are an equal opportunities employer and 94% of our staff are on the same basic salary and commission regardless of gender. In addition, three out of eight board directors are female.