Company Policies

1. Policy Statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour, and human trafficking (“modern slavery”), all of which include the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Zest Promotional has a zero-tolerance approach to modern slavery within its business and supply chains.

This policy applies to all persons:

Zest Promotional is committed to:

We expect the same high standards from all of our Suppliers. As part of our contracting process, we include specific prohibitions against modern slavery, and we expect that our Suppliers will hold their own suppliers to the same high standards.

2. Identifying Modern Slavery

Modern slavery may be found in:

There is no typical victim of modern slavery, and some victims do not understand they have been exploited and are entitled to help and support. However, the following key signs could indicate that someone may be a victim of modern slavery or human trafficking:

The above list is not exhaustive. A person may display a number of the indicators set out above, but they may not necessarily be a victim of slavery or trafficking.

3. Responsibility for this Policy and Compliance

• The Management Board has overall responsibility for ensuring this policy complies with Zest Promotional’s legal and ethical obligations.
• The Legal Team has primary responsibility for implementing this policy, and dealing with any queries about it.
• All Zest Promotional Staff members must comply with this policy.
• All Suppliers must comply with this policy.

4. Reporting Modern Slavery

Zest Promotional Staff and Suppliers must report any incidence or suspicion of modern slavery at the earliest possible stage to:

5. Publication of this Policy

• This policy is available to staff, suppliers and the general public on the Zest Promotional website.

6. Breaches of this Policy

• Any Zest Promotional staff member who breaches this policy may face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
• The relevant member of Zest Promotional may terminate its relationship with a Supplier if it is in breach of this policy. Alternatively, the relevant member of Zest Promotional may elect to work with the Supplier to resolve such issues.

7. Policy Review

• The company’s lead executive, CEO or Managing Director, in conjunction with the Human Resources and Legal team is responsible for reviewing this policy as necessary to ensure that it meets legal and ethical requirements and reflects best practice.
• This policy does not form part of any contract of employment and may be amended at any time.
• Zest Promotional members are invited to comment on this policy and suggest ways in which it might be improved by emailing feedback to antony@zestpromotional.com.

Policy last reviewed 08.08.2022 — by Antony Showman.

What are cookies?

Cookies are small text files that are placed on your computer, tablet or mobile device when you visit a website. They are widely used to make websites work, to improve efficiency, and to provide information to the site owner. Some cookies are essential to how a site functions; others are optional and help us understand how the site is used.

This Cookie Policy explains how Zest Promotional uses cookies on www.zestpromotional.com and the choices available to you. It should be read alongside our Privacy Policy. For the most current, automatically updated version of this policy, please see our Cookie Policy (UK) page.

How we use cookies

We use cookies in the following categories:

Category	Purpose	Examples
Strictly necessary	Required for the website to function and cannot be switched off in our systems. They are usually set in response to actions you take, such as setting your privacy preferences, logging in, or completing forms. They do not store personally identifiable information.	WordPress and Elementor session cookies; your cookie consent preference.
Functional	Enable enhanced functionality, such as our live chat service. These cookies may be set by third-party providers whose services we use on our pages.	Tawk.to live chat: e.g. __tawkuuid, TawkConnectionTime.
Analytics	Help us understand how visitors use our website by collecting and reporting information anonymously — for example, which pages are most visited and how people move through the site. This helps us improve how the site works.	Google Analytics (GA4): _ga, _ga_*.

Third-party cookies

We use Google Analytics (GA4), a web analytics service provided by Google, to help analyse how visitors use our site. Google Analytics sets cookies to collect standard internet log information and visitor behaviour information in an anonymous form. This information is processed in line with Google’s Privacy Policy. You can opt out of Google Analytics across all websites by installing the Google Analytics Opt-out Browser Add-on.

We also use Tawk.to to provide live chat on our website. Tawk.to sets functional cookies to enable the chat service and to remember your chat session. This information is processed in line with the Tawk.to Privacy Policy.

Managing your cookies

You can control and manage cookies in several ways. Most web browsers allow you to refuse or accept cookies, delete existing cookies, and be notified when a new cookie is set. The method varies by browser — check your browser’s help section for instructions. Please note that if you block or delete cookies, some parts of the website may not function correctly.

Useful guidance for the main browsers is available from each browser provider, and general information about cookies can be found at www.aboutcookies.org.

Changes to this Cookie Policy

We may update this Cookie Policy from time to time to reflect changes to the cookies we use or for operational, legal or regulatory reasons. Any changes will be published on this page.

Contact

If you have any questions about our use of cookies, please email sales@zestpromotional.com or call 0161 672 5804.

Last updated June 2026.

1. Policy Statement

Zest Promotional is committed to promoting equality of opportunity, valuing diversity, and creating an inclusive environment for all employees, workers, contractors, suppliers, customers and visitors. We believe that everyone has the right to be treated with dignity and respect.

Zest Promotional has a zero-tolerance approach to discrimination, harassment and victimisation of any kind. We are committed to complying with the Equality Act 2010 and all other applicable equality legislation.

This policy applies to all aspects of our business, including recruitment and selection, terms and conditions of employment, training and development, promotion, pay and benefits, conduct at work, disciplinary and grievance procedures, and the provision of products and services.

2. Purpose

The purpose of this policy is to:

3. Protected Characteristics

Under the Equality Act 2010, it is unlawful to discriminate against a person because of any of the following nine protected characteristics:

4. Forms of Discrimination

This policy prohibits the following:

5. Our Commitments

Zest Promotional is committed to:

6. Responsibilities

• The Management Board has overall responsibility for the effective operation of this policy and for ensuring compliance with equality legislation.
• All Zest Promotional staff are responsible for their own conduct and must not discriminate against, harass or victimise others. Staff must treat colleagues, customers, suppliers and visitors with dignity and respect.
• Suppliers and contractors working with Zest Promotional are expected to uphold the principles of this policy.

7. Raising Concerns and Breaches

• Anyone who believes they have been subject to, or has witnessed, discrimination, harassment or victimisation should raise the matter at the earliest opportunity. Employees should report concerns to their Line Manager; suppliers and customers should contact their primary business contact at Zest Promotional or email sales@zestpromotional.com.
• All concerns will be taken seriously, treated in confidence so far as possible, and investigated promptly. No individual will be penalised for raising a genuine concern.
• Any member of staff who breaches this policy may face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

8. Policy Review

• This policy will be reviewed as necessary to ensure it continues to meet legal requirements and reflects best practice.
• This policy does not form part of any contract of employment and may be amended at any time.

Policy last reviewed June 2026 by Antony Showman.

Introduction

What follows below is the official Zest Promotional Privacy Policy. Above all, Emmy Trading Ltd t/a Zest Promotional is committed to protecting the privacy and security of your personal information.

Firstly, this privacy notice describes how we collect, use and store personal information about you during and after your business relationship with us, in accordance with the General Data Protection Regulation (EU 2016/679) (GDPR).

Secondly, Emmy Trading Ltd t/a Zest Promotional is a “data controller”. Consequently, we are responsible for deciding how we hold, use and store personal information about you. Likewise, we are required under the GDPR to notify you of the information contained in this privacy notice.

To sum up, we may update this notice at any time. Finally, it is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using your personal information.

Data protection principles

We will comply with all relevant data protection law (including the GDPR). This requires that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.

The kind of information we hold about you

We may collect, store, and use the following categories of personal information about you:

• Personal contact details such as name, title, address, telephone numbers, personal/business email addresses and IP address.
• Payment card information when you purchase our products or services. We use third-party processors including Worldpay (view their Privacy Policy) and PayPal (view their Privacy Policy).

How we will use information about you

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

• Need to perform the contract we have entered into with you.
• Must process the orders that you have placed with us.
• Need to administer your account with us.
• Seek your views on the products and services that we provide.
• Must notify you of changes to our products and services.
• Send you information about other products or services you have sought from us.
• Need to comply with a legal or regulatory obligation.

Additionally:

• We may need to process a job application or respond to an enquiry about a possible job with 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.

We may also use your personal information in the following situations, which are likely to be rare:

• Where we need to protect your interests (or someone else’s interests).
• Where it is needed in the public interest or for official purposes.

Situations in which we will use your personal information

We need all the categories of information detailed in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal and regulatory obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.

• Administering the contract we have entered into with you and providing our products and services to you.
• Making arrangements for the termination of our contracting relationship.
• Dealing with legal disputes involving you, or any disputes that may arise under the contract that we have with you or the way in which we provide our products and services to you.
• To prevent fraud.

Some of the above grounds for processing will overlap. Therefore, there may be several grounds which justify our use of your personal information.

If you fail to provide personal information

If you fail to provide certain personal information when requested by us, we may not be able to perform the contract we have entered into with you (such as providing you with our services or guarantees), or we may be prevented from complying with our legal obligations (such as financial and tax reporting and insurance maintenance).

Choices you have with your personal information

We will not contact you for marketing purposes by email, phone or text message unless you have given your prior consent. We will not contact you for marketing purposes by post if you have indicated that you do not wish to be contacted. You can change your marketing preferences at any time by contacting us by email: sales@zestpromotional.com or write to us at 11-15 New Road, Radcliffe, Manchester, M26 1LS.

Change of purpose

We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you in writing and we will explain the legal basis which allows us to do so.

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

How we use sensitive information

“Special categories” of sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

• In limited circumstances, with your explicit written consent.
• Where we need to carry out our legal obligations and in line with our Data Protection Policy.
• Where it is needed in the public interest, and in line with our Data Protection Policy.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of providing contracted services/products to you. In limited circumstances, we may approach you for your written consent to allow us to process sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

Cookies

Like many other websites, the www.zestpromotional.com website uses cookies. ‘Cookies’ are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual. For example, we use cookies to store your country preference. This helps us to improve our website and deliver a better, more personalised service.

It is possible to switch off cookies by setting your browser preferences. For more information on how to switch off cookies on your computer, visit our full cookies policy. Turning cookies off may result in a loss of functionality when using our website.

Data sharing

We may have to share your data with third parties (listed in the next section), including third-party service providers. Consequently, we require third parties to respect the security of your data and to treat it in accordance with the law, and we will have a contract in place with each of these third parties to ensure the protection of your personal information.

Why might we share my personal information with third parties?

We may share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

“Third parties” includes third-party service providers (including contractors and designated agents). In particular, the following activities are carried out by third-party service providers:

• Edwards Veeder (UK) Limited — Payroll & Pension Administration
• Eurotek UK Limited — IT Services
• Customer Focus Limited — IT Services
• DHL UK Ltd — Distribution
• World Options — Distribution
• One Post — Mailings
• Tawk.to — live chat software on our website. This is provided by Tawk.to, a third-party live chat provider. Information on how data is processed and stored is set out in the Tawk.to Privacy Policy.

How secure is my information with third-party service providers?

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies, and this is supported by a contractual agreement with clear obligations on the third parties. As an example, we do not allow our third-party service providers to use your personal data for their own purposes. Usually, we only permit them to process your personal data for specified purposes and in accordance with our written instructions.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

Data security

We have put in place appropriate technical and security measures to protect the security of your personal information. Details of these measures are available upon request. Third parties will only process your personal information on our written instructions and where they have agreed to treat the information confidentially and to keep it secure as part of their contractual arrangement with us.

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

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

Data retention

We will only retain your personal information 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. Details of retention periods for different aspects of your personal information are available in our retention policy and are available upon request. 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, the purposes for which we process it and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a customer of the company, we will retain and securely destroy your personal information in accordance with our data retention policy or current applicable laws and regulations.

Rights of access, correction, erasure and restriction

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us. Under certain circumstances, by law, you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”).
• Request correction of the personal information that we hold about you.
• Request erasure of your personal information.
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party).
• Request the restriction of processing of your personal information.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data or request that we transfer a copy of your personal information to another party, please contact your Manager in writing.

No fee usually required

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

What we may need from you

We may need to request specific information, such as a certified copy of your passport, from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure that ensures we don’t disseminate personal information to any person who has no right to receive it.

Right to withdraw consent

There may be circumstances where you’ve provided consent to the collection, processing and transfer of personal information for specific purposes. In that instance, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officer in writing. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO). The ICO is the UK supervisory authority for data protection issues.

Data protection officer (DPO)

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO.

Changes to the Zest Promotional Privacy Policy

We reserve the right to update this privacy notice at any time; consequently, we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways infrequently about the processing of your personal information. If you have any questions about this privacy notice, please contact the DPO.

Introduction

Our business is committed to lowering the carbon footprint of the business and its people, whilst ensuring positive environmental and social impacts can be made on the journey to net zero.

This policy covers 9 key programme areas, as per the net zero framework which is used to assess, plan and take action in order to make positive change for the planet and its people. The nine key programme areas are: Governance, Energy & Emissions, Food, Procurement, Transportation, Facilities, Resource Use & Waste, Water, and Projects & Workforce.

The information gathered has been and will be used to set annual objectives and targets. We recognise improving environmental performance requires changes in the way we carry out our day-to-day business, which must nevertheless be consistent with our health and safety obligations, and also requires the support of every member of staff.

Supportive of Global Action on Climate Change, Biodiversity and Sustainability

Climate change is a global emergency that goes beyond national borders. It is an issue that requires international cooperation and coordinated solutions at all levels. Our policy supports the global commitment made by 192 countries and the EU towards the Paris Agreement, a legally binding international treaty, to substantially lower greenhouse gas emissions and pursue efforts to limit the increase beyond 1.5 degrees. Our policy also supports the 2019 UK law requiring net zero greenhouse gas emissions by 2050. Our commitment supports NASA’s view that humanity must respond to climate change through mitigation and adaption.

In support of the Nature Conservation (Scotland) Act 2004 we will act to further the conservation of biodiversity, taking the impact on biodiversity into account in all aspects of our decision-making — e.g. operations such as purchasing of supplies, disposal of waste, use of paper, and water and energy resources.

In 2015, world leaders at the United Nations (UN) agreed on 17 Sustainable Development Goals (SDGs) that would create a better world by 2030. These goals focus on eradicating poverty, fighting inequality and ending climate change. This policy recognises sustainability and net-zero are two different terms. Net-zero means leaving no carbon footprint (greenhouse gases put into atmosphere = greenhouse gases taken out). Sustainability is a wider concept, that includes climate action, that looks to the 17 UN SDGs as a road map to greater sustainability. As these 17 goals are not only focused on the environment, but include greater equality, fair wages, and investing in diversity, our support to these areas is covered in other policies.

Zest Promotional operations deliver positive action on 11 of the 17 Sustainable Development Goals — 10 through tree planting with Eden Reforestation: 1 No Poverty, 2 Zero Hunger, 3 Good Health and Well-being, 5 Gender Equality, 8 Decent Work & Economic Growth, 10 Reduced Inequalities, 13 Climate Action, 14 Life Below Water, 15 Life on Land and 17 Partnership for the Goals. The 11th SDG to be met is 4 Quality Education, as we provide regular weekly education on sustainable and environmental action.

The 9 key programme areas that will take our business to net zero

Governance. The business is committed to having sustainability within the strategy, setting long-term and annual objectives in this area. To ensure continuity of delivery, training and measurement there will be a sustainability lead on the board, the staff and a sustainability team. There will be a commitment to education, regularly measuring our status and appropriate policies being put into place — e.g. Anti-Slavery, Equality & Diversity, Environmental, etc. We recognise that to succeed, sustainability must play a key role in our governance, operations and outward profile.

Energy. The business is committed to less energy waste and greener energy. This includes assessing energy use, energy supply, opportunities to self-generate and ensuring energy efficiency within buildings and initiatives to reduce energy use.

Food. Where appropriate the business is committed to reducing the footprint of food intake and use by using vegetarian meals, vendors, local and ethical producers of food, growing our own and reducing food waste by not over-ordering and a commitment to composting.

Procurement. Eco and ethical assessment of the supply chain, working with suppliers on shared sustainability goals, choosing greener products and services including a commitment to plastic alternatives. Implement a sourcing policy that prioritises: reuse over single use, renewable over finite resources, certified compostable products (where they exist) and prioritising products with the highest recycled content available (min 30%).

Transportation. A commitment to lowering the footprint of all aspects of transportation involved in the business. This includes its vehicle fleet, pool cars, charging points, compliance with ULEZ standards, using venues with good public transport links and staff support — e.g. car sharing, bike to work, e-bikes, walking and encouraging use of public transport.

Facilities. Exploring opportunities to self-generate our own energy — wind, solar, biomass power — within the facilities. Monitor, maintain and improve the biodiversity and biosecurity within the grounds of the facility. A commitment to creating green areas (inside and out), improving air quality and maximising the use of natural light.

Resource Use and Waste. A commitment to measure waste impact then target zero waste to landfill through reuse and recycling options. Assess the use of packaging on the same principles and, where appropriate, avoid single-use plastics and go paperless. Promoting the circular economy with a positive green message: refuse, repair, reuse and recycle.

Water. To minimise water consumption and waste, exploring reusing grey water, providing water for refillable bottles and supporting innovative tech and engineering in this area.

Projects and Workforce. A commitment to educate the workforce, customers and partners on sustainability and the environmental policy. If appropriate, encourage working from home, teleconferencing over travel, and the use of digital documentation in place of printing. We will continue to set, measure and review annual objectives across all nine programme areas as we progress towards net zero, and we welcome ideas from staff, customers and partners on how we can do more.

Policy last reviewed June 2026.