Compliance Policy

1. Purpose

The development of internal rules and procedures but also a strict application control system through which business integrity is ensured.

2. Principles

Honesty, Integrity and Non-bias are basic principles in the operation of MAGIC UMBRELLA LIMITED and all business activities developed and related to its associates must reflect these principles.

2.1. MAGIC UMBRELLA LIMITED (hereinafter “Company” or “MAGIC UMBRELLA”) is active in a large number of industries and sectors, keeping high quality levels, and strongly considers that the compliance program developed is an additional advantage to its practice and business associations.

2.2. The development and adoption of compliance rules, apart from its ethical dimension, is also a component for a realistic and effective approach to the risk management and preservation of the company’s reputation.

2.3. We adhere to the basic principle that all business transactions, partnerships, collaboration as well as communication with suppliers, recruitment agencies and contractors shall be characterised by moral correctness and legitimacy.

2.4. MAGIC UMBRELLA fully complies with all legislation and rules that apply to its industry and continually develops internal control systems for its compliance to this institutional framework. The complexity and fragmentation of legislation, including tax legislation, whether derived from the national regulatory framework or the corresponding set of international rules, is a practice found in Umbrella Companies industry sector, and MAGIC UMBRELLA in the context of corporate compliance, decrypts the entire institutional system and communicates it to all its business partners, employees and contractors. The Company’s activities are conducted in full compliance with all the national and international laws and regulations governing this particular industry.

2.5. Moreover, MAGIC UMBRELLA is a member of the Professional Passport, the largest independent assessor of payment intermediary compliance, and in addition to the international and national legislative framework, it follows the strict framework of rules that is dictated by IR35 legislation in matters of compliance.

2.6. An effective corporate compliance program, for MAGIC UMBRELLA, is a priority and works on the prevention of negative behaviours and situations. The Company pays special attention to the identification of possible risks in matters of corruption, plans and applies inspections in advance, in order to have a safety net, with monitoring procedures and report of the effectiveness of these inspections in managing the company’s exposure to risks. Within this framework it resolves any weaknesses that may appear in the level of Compliance Policy.

3. Responsibility

Prevention is the most important to avoid behaviours on part of the associates that do not comply with the rules of ethics and legal order it has adopted and for this reason it has developed proper internal procedures and policies.

3.1. Our Company believes that an integrated compliance program, creates a mechanism to guarantee its good function, in accordance with the institutional framework of rules, thus gaining significant additional benefits in its business activity, in the direction for ensuring transparency, in all stages of business structure.

3.2. The benefits secured by the implementation of a complete and well-structured compliance program include:

commitment for honest and responsible corporate behaviour;
development and application of tactics, effective training programs and evaluation of personnel in matters of Regulatory Compliance; and
creation and maintenance of an effective communication line with the Company personnel so that the tracing at first and then the solution of matters of proper implementation of compliance standards is performed immediately and uninterrupted.

3.3. The program of regulatory compliance includes procedures and practices followed by the Company and has been communicated adequately, so that the Company personnel working behaviour is adjusted.

3.4. Company personnel must apply to the company’s compliance rules and adhere to their day-to-day activity. These Policies and Procedures define as well the manner of association that the company adopts with third parties, external associates and service agents.

3.5. The Company plans and implements personnel training programs in matters of compliance, so that all services are performed with integrity and professional honesty, ensuring that all Company personnel have knowledge and understanding of the current institutional framework against bribing and corruption as well as the code of ethics and that they act accordingly. Offers adequate training to all Company personnel including seminars, presentations, case studies but also training material available online. Activities and procedures of internal control are applied immediately when omissions are identified that may lower the high standards applied by the company.

Priority is the training of the whole company and the adoption of practices which will ensure the highest possible level of compliance.

3.6. Part of global economy, MAGIC UMBRELLA, operates in a way that responds to the fundamental principles of the human rights, labour and the environment. The United Nations Sustainable Development Goals are a challenge for our company to engage in responsible business activity, with the incorporation of the Ten Globally Acceptable Principles of the United Nations Organisation, one of which is the fight against corruption. Our Policy for this principle, is realised in the compliance program, as it has been developed in our Company.

3.7. The values of MAGIC UMBRELLA are respect to the human, honesty, trust and transparency. Our commitment for honesty and integrity is especially important in the prevention and identification of corruption fields and in this section we apply zero tolerance Policy.

3.8. In any actions opposing the good professional practice, we prioritise our principles operating with honesty, respect and responsibility.

4. Compliance Obligations

4.1. The Company is committed to complying with all relevant laws and regulations, as amended and in force, including but not limited to:

Companies Act 2006.
HMRC guidelines for Compliance.
Data Protection Act 2018.
IR35 legislation.
VAT / Tax legislation & regulations.
Finance Act 2015.
Agency Workers Regulations 2010.
Equal Opportunity Act 2010.
Employment Rights Act 1996.
UK Bribery Act 2010.
Health & Safety at Work Act 1974.
Modern Slavery Act 2015.

5. Code of Conduct

5.1. All Company directors, officers, associates, business partners and employees (“Company personnel”) are expected to adhere to the highest standards of ethical conduct, including:

Acting with integrity and honesty in all business dealings.
Avoiding conflicts of interest and disclosing any potential conflicts.
Protecting the Company’s assets and ensuring their proper use.
Maintaining the confidentiality of Company information.
Respecting and promoting human rights.
Reporting any suspected violations of laws, regulations, or Company policies.

6. Anti-Bribery & Corruption

6.1. The Company has a zero-tolerance Policy towards bribery and corruption.

6.2. Therefore, Company personnel must not:

Offer, give, solicit, or accept bribes or other improper payments to gain business or personal advantages.
Engage in any form of corruption or unethical behaviour.

6.3. Company personnel must report any concerns or suspicions regarding bribery or corruption to the Legal Compliance Officer immediately.

7. Data Protection

7.1. Within the framework of the Data Protection Act 2018, which is the UK’s implementation of the European General Data Protection Regulation (“UK-GDPR”), the Company adapts its internal processes and policies for the processing of employee-associate personal data and the protection of the rights of these natural persons so as to ensure confidentiality, integrity and availability of their data.

7.2. MAGIC UMBRELLA creates a grid to strengthen the internal policies and processes, achieving its readiness to fulfil its obligations under the new set of rights of data subjects. Employee information is considered to be particularly important and therefore awareness-raising activities are being carried out.

7.3. The Company and Company personnel must:

Collect, use and store personal data only for legitimate business purposes.
Ensure that personal data is accurate and up-to-date.
Implement appropriate security measures to protect personal data.
Report any data breaches immediately to the Data Protection Officer.

8. Health & Safety

8.1. The Company is dedicated to providing a safe and healthy work environment.

8.2. Company personnel must:

Comply with all health and safety laws and regulations.
Follow all Company health and safety policies and procedures.
Report any health and safety hazards or incidents immediately.

9. Employment Practices

9.1. The Company is committed to fair and equitable treatment of all Company personnel.

9.2. This includes:

Prohibiting discrimination, harassment, and bullying.
Providing equal employment opportunities.
Ensuring fair wages and benefits.
Complying with all employment laws and regulations.

10. Whistleblowing

10.1. The Company encourages Company personnel to report any suspected illegal or unethical behaviour.

10.2. The Company will:

Provide a confidential and secure means for reporting concerns.
Protect whistle-blowers from retaliation.
Investigate all reports promptly and thoroughly.

11. Training & Communication

11.1. The Company will provide regular training and communication to ensure that all Company personnel understand their compliance obligations.

11.2. This includes:

Induction training for new Company personnel.
Ongoing training and updates for all Company personnel.
Clear communication of this Policy and related procedures.

12. Monitoring, Audit & Enforcement

12.1. The Company will monitor compliance with this Policy through regular audits and reviews.

12.2. Any employee found to be in violation of this Policy may face disciplinary action, up to and including termination of employment.

13. Policy Review

This Policy will be reviewed yearly and updated as necessary to reflect changes in laws, regulations, and Company operations.

Contact Information

For questions and/or concerns regarding this Policy, please do not hesitate to contact our Legal Compliance Department at: legal@magic-umbrella.co.uk.

Last modified: January 2025