High Level Photography Limited has a zero-tolerance approach to slavery and is committed to preventing acts of slavery and human trafficking from occurring within both its business and supply chain, and imposes those same high standards on its contractors, suppliers and other business partners.

- Operate a procurement process, ensuring suppliers comply with all applicable laws and standards, including those which relate to the Modern Slavery Act;
- Expect our suppliers to have suitable anti-slavery and human trafficking policies and processes in place within their own businesses and to cascade those policies to their own suppliers;
- Have added a specific item relating to the Modern Slavery Act to the agenda of the contract management meetings with suppliers enabling us to be kept informed of any changes;
- Encourage staff to identify and report any potential breaches of High Level’s anti-slavery policy statement;
- Whistle blowers are protected through our confidential reporting process.

The above procedures are designed to:
- Identify and assess potential risk areas in our business and supply chains.
- Reduce the risk of slavery and human trafficking occurring in our business and supply chains.
- Monitor potential risk areas in our business and supply chains.
- Provide adequate protection for whistle blowers.
This policy by High Level Photography Ltd sets out the minimum standards expected from staff in their internal and external dealings with colleagues and customers. Compliance with this policy will be continuously monitored and subject to review by management.

Basic Standards of Conduct
- We will conduct every aspect of our business with honesty, integrity and openness, respecting human rights and the interests of our employees and customers.
- We will maintain the highest standards of integrity – for example, we will not promise more than we can reasonably deliver or make commitments we cannot or do not intend to keep.

High Level Photography recognises that our people are our greatest asset and key to continued growth and success and as such, we are committed to providing careers and working environments in which our people can achieve their fullest potential.
The High Level management:- - are committed to creating and maintaining a safe and healthy working environment for employees.
- will strive to create a workplace in which there is mutual trust and respect and where every person feels responsible for the performance and reputation of our company.

Equal Opportunities
High Level is committed to a policy of equal opportunity and diversity in employment and recognises that this is essential to ensuring the success and growth of the organisation. To this end, we make every effort to select, recruit, train and promote the best candidates based on suitability for the job; regardless of race, sex, marital status, age, nationality, ethnic origin, religious belief, sexual orientation or disability; and to ensure that no employee suffers harassment or intimidation.

Disabled Employees
It is policy to provide employment and to make reasonable adjustment to accommodate disabled persons wherever business requirements will allow. Should an existing employee become disabled, every reasonable effort will be made to ensure that their employment can continue on a worthwhile basis and that career opportunities are available to them.

Environmental Issues
High Level is committed to making continuous improvement in the management of its environmental impact.

High Level is committed to providing safe, value for money, high quality, consistent, accessible and reliable services to its customers.
What does this policy cover?
This anti-bribery policy exists to set out the responsibilities of High Level Photography Ltd and those who work for us in regard to observing and upholding our zero-tolerance position on bribery and corruption. It also exists to act as a source of information and guidance for those working for High Level Photography Ltd. It helps them recognise and deal with bribery and corruption issues, as well as understand their responsibilities.

Policy statement
High Level Photography Ltd is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented. High Level Photography Ltd has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.

High Level Photography Ltd will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, in regards to our conduct both at home and abroad.

High Level Photography Ltd recognises that bribery and corruption are punishable by up to ten years of imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business, and take our legal responsibilities seriously.

Who is covered by the policy?
This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK). The policy also applies to Officers, Trustees, Board, and/or Committee members at any level.

In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.

Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum.

Definition of bribery
Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision.

A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.

Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.

Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company’s Managing Director.

What is and what is NOT acceptable
This section of the policy refers to 4 areas:
Gifts and hospitality.
Facilitation payments.
Political contributions.
Charitable contributions.

Gifts and hospitality
High Level Photography Ltd accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements: It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits.

It is not made with the suggestion that a return favour is expected.
It is in compliance with local law.
It is given in the name of the company, not in an individual’s name.
It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).
It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).
It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.
It is given/received openly, not secretly.
It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.
It is not above a certain excessive value, as pre-determined by the company’s Managing Director (usually in excess of £100).
It is not offer to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s Managing Director.
Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted so long as it is declared to the Managing Director, who will assess the circumstances.
High Level Photography Ltd recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each.
As good practice, gifts given and received should always be disclosed to the Managing Director. Gifts from suppliers should always be disclosed.
The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the Managing Director should be sought.

Facilitation Payments and Kickbacks
High Level Photography Ltd does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action.

High Level Photography Ltd does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.

High Level Photography Ltd recognises that, despite our strict policy on facilitation payments and kickbacks, employees may face a situation where avoiding a facilitation payment or kickback may put their family’s personal security at risk. Under these circumstances, the following steps must be taken:

Keep any amount to the minimum.
Ask for a receipt, detailing the amount and reason for the payment.
Create a record concerning the payment.
Report this incident to your line manager.

Political Contributions
High Level Photography Ltd will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage.

Charitable Contributions
High Level Photography Ltd accepts (and indeed encourages) the act of donating to charities – whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes.
Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery.

We will ensure that all charitable donations made are legal and ethical under local laws and practices, and that donations are not offered/made without the approval of the Managing Director.

Employee Responsibilities
As an employee of High Level Photography Ltd, you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other anti-bribery and corruption information you are given.

All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy.

If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must notify the Managing Director.

If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. High Level Photography Ltd has the right to terminate a contractual relationship with an employee if they breach this anti-bribery policy.

What happens if I need to raise a concern?
This section of the policy covers 3 areas:
How to raise a concern.
What to do if you are a victim of bribery or corruption.

How to raise a concern
If you suspect that there is an instance of bribery or corrupt activities occurring in relation to High Level Photography Ltd, you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behaviour can be considered bribery or corruption, you should speak to your line manager and Managing Director.

High Level Photography Ltd will familiarise all employees with its whistleblowing procedures so employees can vocalise their concerns swiftly and confidentially.

What to do if you are a victim of bribery or corruption
You must tell your Managing Director as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity.

If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of bribery or corruption, High Level Photography Ltd understands that you may feel worried about potential repercussions. High Level Photography Ltd will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken.

High Level Photography Ltd will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption.

Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in relation to the concern the individual raised.

If you have reason to believe you’ve been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, you should inform your line manager or the Managing Director immediately.

Training and Communication
High Level Photography Ltd will provide training on this policy as part of the induction process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy, and will be asked annually to formally accept that they will comply with this policy.

High Level photography Ltd’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third parties at the outset of business relations, and as appropriate thereafter.

High Level Photography Ltd will provide relevant anti-bribery and corruption training to employees etc. where we feel their knowledge of how to comply with the Bribery Act needs to be enhanced. As good practice, all businesses should provide their employees with antibribery training where there is a potential risk of facing bribery or corruption during work activities.

Record keeping
High Level Photography will keep detailed and accurate financial records, and will have appropriate internal controls in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given, and understand that gifts and acts of hospitality are subject to managerial review.

Monitoring and Reviewing
High Level Photography’s Managing Director is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness.

Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice.

Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the Managing Director.

This policy does not form part of an employee’s contract of employment and High Level may amend it at any time so to improve its effectiveness at combatting bribery and corruption.
This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.highlevelphotography.co.uk, including any information you may provide through our site when you purchase a product or service, sign up to our newsletter or take part in a prize draw or competition.

By providing us with your data, you warrant to us that you are over 13 years of age.

High Level Photography Ltd are the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

Contact Details

Our full details are: Full name of legal entity: High Level Photography Ltd
Email address: info@highlevel.co.uk
Postal address: Building D4, Fairoaks Airport, Chobham, Surrey, GU24 8HU
[Telephone number:] 020 3355 0274

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at Info@highlevel.co.uk.


Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process certain types of personal data about you as follows:
• Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.
• Contact Data may include your billing address, delivery address, email address and telephone numbers.
• Financial Data may include your bank account and payment card details.
• Transaction Data may include details about payments between us and other details of purchases made by you.
• Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
• Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
• Usage Data may include information about how you use our website, products and services.
• Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.

We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.


We collect data about you through a variety of different methods including:
• Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
• order our products or services;
• create an account on our site;
• subscribe to our service or publications;
• request resources or marketing be sent to you;
• enter a competition, prize draw, promotion or survey; or
• give us feedback.
• Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies.


We will only use your personal data when legally permitted. The most common uses of your personal data are:
• Where we need to perform the contract between us.
• 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 ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at info@highlevel.co.uk.

Purposes for processing your personal data

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
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 email us at info@highlevel.co.uk 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 below.

Type of data
Lawful basis for processing

To register you as a new customer
(a) Identity
(b) Contact Details

Performance of a contract with you

To process and deliver your order 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

Performance of a contract with you
Necessary for our legitimate interests to recover debts owed to us

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) Profile
(d) Marketing and Communications

Performance of a contract with you
Necessary to comply with a legal obligation
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) Profile
(d) Usage
(e) Marketing and Communications

Performance of a contract with you
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 our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical

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
Necessary to comply with a legal obligation

To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) 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 use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(a) Technical
(b) Usage

Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop 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
(e) Profile

Necessary for our legitimate interests to develop our products/services and grow our business

Marketing communications
You will receive marketing communications from us if you have:
(i) requested information from us or purchased goods or services from us; or
(ii) if you provided us with your details when you entered a competition or registered for a promotion or free resources; and
(iii) in each case, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by emailing us at info@highlevel.co.uk.

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

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 find out more about how the processing for the new purpose is compatible with the original purpose, please email us at info@highlevel.co.uk.

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.


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:
• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.


We do not transfer your personal data outside the European Economic Area (EEA).


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 such data. 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.


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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see 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.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
You can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ If you wish to exercise any of the rights set out above, please email us at info@highlevel.co.uk.

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.

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.

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.


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.


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