Privacy Policies

Ethical Trading Policy
Summary Statement:

At Gemcom Ltd, we believe strongly in ethical principles and good stewardship. We are therefor proud to guarantee that we trade according to the following Ethical Trading Criteria:

  1. All employment is freely chosen
  2. Working conditions are safe and hygienic.
  3. Child labour is not used.
  4. Wages are fair and comparable to industry standard and will always exceed the minimum wage.
  5. Deductions from wages as a disciplinary measure shall not be permitted.
  6. Working hours are not excessive.
  7. No discrimination is practised.
  8. Regular employment is provided for those who are employed on a permanent contract.
  9. No harsh, cruel or degrading treatment or practices are allowed.
  10. No bribery, corruption, blackmailing or bullying is permitted.
  11. Third Party Suppliers and buyers are both free to sell and buy from any number of other businesses. No restrictions, as a way of guaranteeing business, are allowed.

Our Full Ethical Trade Policy Statement:
Gemcom Ltd. recognises that our commercial activities have potential to impact on our suppliers and our locality.

As a socially responsible small business our suppliers, local community and customers have a right to expect:

  • Products distributed and sourced by Gemcom Ltd. are produced under working conditions that are hygienic and safe.
  • All workers involved in the delivery of services provided by Gemcom Ltd are treated with full consideration to their basic human rights.
  • Gemcom Ltd. acts in an ethical manner above and beyond basic legal requirements.
  • Gemcom Ltd. is therefore committed to implementing the principles of the Ethical Trading Initiative Base Code (although we are not members of the ETI). (R-003)
  • This policy sets out Gemcom Ltd commitment, setting out the measures we are taking to ensure that we are acting in an ethical manner.

Commitment to our suppliers, service providers and customers:
Gemcom Ltd recognises that our ethical and social performance and reputation is a key part of our overall commercial success.

Gemcom Ltd is committed to ensuring that our employment practices and the enforcement of corporate regulations ensure the protection of the rights of all those who work for us. In many areas we aim to operate above the minimum standards required by law to ensure our employees are safe, rewarded and valued. As we of course expand and become larger we will be able to offer more opportunities for our staff.

Gemcom Ltd Ethical Trading Code of Practice:

1. This Code of Practice applies to:

  • Staff directly employed by Gemcom Ltd on temporary or permanent contracts.
  • Staff employed or provided by contractors or employment agencies to work on Gemcom premises or to undertake work for or on behalf of Gemcom Ltd.

2. No forced, bonded or involuntary labour shall be used.

  • All employment with Gemcom Ltd. is freely chosen.
  • Staff are not required to lodge deposits or identity papers with us.
  • Staff are free to leave Gemcom after reasonable notice.

3. No child labour shall be used

  • There shall be no recruitment of child labour.
  • Children or persons under 16 are not employed at any time, day or night.
  • Children or persons under 18 are not employed full-time.

4. Working conditions are safe and hygienic.

  • Gemcom Ltd. takes adequate measures to prevent accidents and minimise potential hazards.
  • Staff have unrestricted access to toilet facilities and drinking water.
  • Gemcom Ltd. has a published Health & Safety Policy.

5. Working hours and remuneration are reasonable and comparable to other companies in our sector and regular employment is provided.

  • Staff pay rates are above the national legal minimum standards.
  • Staff are not forced to work in excess of 48 hours per week, a voluntary opt out agreement is available for those wishing to work in excess of 48 hours per week.
  • Staff are given written terms and conditions of employment that details the employment relationship between and the respective obligations of the employee and employer, rates of pay, working hours, grievance and disciplinary procedures, holiday entitlement, absence and sick pay rules and notice periods for termination of employment.
  • No deductions are made from wages as a disciplinary measure, and pay slips detailing lawful deductions are provided for each pay period.
  • Labour only contracting, sub contracting and fixed term contracts are not used as a means to avoid obligations under labour or social security laws.

6. No discrimination is practised

  • There is no discrimination in pay, hiring, compensation, access to training, promotion, and termination of employment or retirement on the grounds of race, nationality, religion, age,
    disability, marital status, sexual orientation, union membership or political affiliation.
  • Opportunities for personal and career development are equally available to all employees.
  • No harassment, threats, abuse or intimidation shall be practised. Physical, verbal and sexual threats, abuse, harassment or intimidation is expressly prohibited and grounds for summary dismissal, if proved.
    Looking towards further improvement Gemcom are keen to learn from others and would ask if anyone has any ideas or feedback regarding our policy or practice to contact us.

Associated Records: –
R-003 Ethical Trading Initiative (ETI) Base Code

Fair Processing Notice (Customers/Suppliers)


On 25th May 208, the New General Data Protection Regulations (GDPR) will legally take effect. As a business which holds personal data relating to your company, we are legally obliged to inform you of what data we hold for you and we will/will not use it.

Gemcom Ltd will be what is known as the ‘Controller’ of the personal data you provide to us. Gemcom Ltd company registration number is 5263274 and our registered address is: 68 Great Portland Street, London, W1W7NG.

Why we need it

We need to know your basic personal data to enable us to fulfil our contractual obligation to you as Customer and Suppliers. We will not collect any personal data from you we do not need to provide and oversee this service to you.

What we do with it

We use data relating to your business to facilitate trading with you and your company and for general correspondence with your staff on a regular basis.
Gemcom Ltd will not sell on this information to a 3rd party.
Gemcom Ltd may pass on your details to a 3rd party in order to fulfil your contractual requirements.

What we need

Unless otherwise agreed with you, we will only collect basic personal data about you, which does not include any special categories or personal information about you (often known as ‘sensitive personal data’).

This information, however, includes;

  • Company Name 
  • Company Address 
  • Company Contacts (Sales/Accounts/Management etc) 
  • Various telephone and fax numbers as supplied by you 
  • Various email addresses as supplied by you 
  • VAT Number or EU equivalent 
  • Bank Account Details 

Where we keep it

We hold Company information within our accounting system (Sage), our Trading/Logistics platform (BlueBERI) and or Email/Communication system (Outlook). Information about your company is backed up and stored on a server for security and loss prevention purposes. Information is also backed up in the cloud via Depositit (GDPR compliant). We are the only party who can access this.

How long we keep it

We will only use and store information for so long as it is required for the purpose it was collected for. How long information will be stored depends on the information in question and what it is being used for. 

We will generally keep your personal data for a minimum of 7 years (from last contract date), after which time it will be destroyed if it is no longer required for the lawful purpose(s) for which it was obtained.

What are your rights 

We want to ensure that you remain in control of your personal data. Part of this is making sure you understand your legal rights, which are as follows:

  • the right to confirmation as to whether we have your personal data and, if we do, to obtain a copy of the personal information we hold (this is known as a data subject access request) 
  • the right to have your data erased (though this will not apply where it is necessary for us to continue to use the data for a lawful reason) 
  • the right to have inaccurate data rectified 
  • the right to object to your data being used for marketing or profiling; and 
  • where technically feasible, you have the right to personal data you have provided to us which we process automatically based on your consent or the performance of a contract. This information will be provided in a common electronic format. 

Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so.

If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office, the UK supervisory authority for data protection issues.

Any questions regarding this notice should be sent to our Data Lead (Edward Klein, 

68 Great Portland Street  London  W1W 7NG

t +44 (0)20 7580 8004  e