By using this website, you certify that you have read and reviewed this Agreement and that you agree to comply with its terms. If you do not want to be bound by the terms of this agreement, you are advised to stop using the website accordingly. Rumpus only grants use and access of this website, its products, and its services to those who have accepted its terms.

Privacy policy

Before you continue using our website, we advise you to read our privacy policy regarding our user data collection. It will help you better understand our practices.

Age restriction

You must be at least 18 (eighteen) years of age before you can use this website. By using this website, you warrant that you are at least 18 years of age and you may legally adhere to this Agreement. Rumpus PR assumes no responsibility for liabilities related to age misrepresentation.

Intellectual property

You agree that all materials, products, and services provided on this website are the property of Rumpus PR, its affiliates, directors, officers, employees, agents, suppliers, or licensors including all copyrights, trade secrets, trademarks, patents, and other intellectual property. You also agree that you will not reproduce or redistribute Rumpus PR’s intellectual property in any way, including electronic, digital, or new trademark registrations.

You grant Rumpus PR a royalty-free and non-exclusive license to display, use, copy, transmit, and broadcast the content you upload and publish. For issues regarding intellectual property claims, you should contact the company in order to come to an agreement.

User accounts

As a user of this website, you may be asked to register with us and provide private information. You are responsible for ensuring the accuracy of this information, and you are responsible for maintaining the safety and security of your identifying information. You are also responsible for all activities that occur under your account or password.

If you think there are any possible issues regarding the security of your account on the website, inform us immediately so we may address them accordingly.

We reserve all rights to terminate accounts, edit or remove content and cancel orders at our sole discretion.

Applicable law

By using this website, you agree that the laws of the United Kingdom, without regard to principles of conflict laws, will govern these terms and conditions, or any dispute of any sort that might come between Rumpus PR and you, or its business partners and associates.

Disputes

Any dispute related in any way to your use of this website or to products you purchase from us shall be arbitrated by UK law and you consent to exclusive jurisdiction and venue of such courts.

Indemnification

You agree to indemnify Rumpus PR and its affiliates and hold Rumpus PR harmless against legal claims and demands that may arise from your use or misuse of our services. We reserve the right to select our own legal counsel.

Limitation on liability

Rumpus PR is not liable for any damages that may occur to you as a result of your misuse of our website. Rumpus PR reserves the right to edit, modify, and change this Agreement at any time. We shall let our users know of these changes through electronic mail. This Agreement is an understanding between Rumpus PR and the user, and this supersedes and replaces all prior agreements regarding the use of this website.

Here at Rumpus PR (“WE”), we take your privacy seriously and are committed to maintaining the trust and confidence of our visitors to our website and subscribers to our newsletter.

Here you’ll find information on how we treat data that we collect from visitors to our website, when someone submits a contact form or when someone subscribes to our newsletter.

Your personal data – what is it?

Personal data relates to a living individual who can be identified from that data.

Identification can be by the information alone or in conjunction with any other information in our possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation 2016/679 (GDPR).

Visitors to our Website

When someone visits our website, we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns.

We collect information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type, referral source, length of visit, entry and exit points and the number of page views).

We do this to find out things such as the number of visitors to the various parts of the site.

This information is only processed in a way which does not identify anyone.

We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.

You can find more information on how cookies are used on this website in the Cookies Policy below.

If we do want to collect personally identifiable information through our website, we will be upfront about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

When You Contact Us Via Our Contact Forms

Our website has forms built using Gravity Forms.

The personal information we collect might include your name, phone number, email address, IP address, and information regarding what pages are accessed and when.

When you use our contact form, the information submitted is emailed to us so that we can correspond with you. Your personal data will be stored in the website’s database. Your data is encrypted with the Gravity Forms Encrypted Fields plugin before it is saved to the database.

We store your data on our website database so that if an email doesn’t get through, we can check the website and access the request to ensure we don’t miss any enquiries or leads.

Security

Our website has HTTPS encryption via a Let’s Encrypt SSL certificate to ensure any data passed between your browser and the web server (where this website is hosted) is encrypted. When you are on a secure page, a lock icon will appear at the bottom of web browsers such as Microsoft Internet Explorer.

Data Retention

Your data saved in the website database will automatically be deleted 1 year after submission.

This website and its database are automatically backed up every day using a third-party service ManageWP. Backups are stored for 90 days in the EU Region.

Eclub

We use Fishbowl for our eclub. When you subscribe to our eclub, we collect your email address, name and marketing permissions consent. Your personal data will be stored in our eclub provider, Fishbowl. By clicking to subscribe to the eclub, you acknowledge that the information you provide will be transferred to Fishbowl for processing in accordance with their Privacy Policy and Terms.

Your data on Fishbowl will be kept for the duration the business is running, and we are them. You can request to be removed anytime by clicking ‘unsubscribe’ in any eclub/mailout or by emailing info@rumpuspr.com.

Change of Ownership

Information about users and visitors, including personal data, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets and only if the recipient of the User or visitor data commits to a privacy notice that has terms substantially consistent with this privacy notice.

Client data may be physically or electronically transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, for the sole purpose of continuing the operation of the Service, and only if the recipient of the client data commits to a privacy notice that has terms substantially consistent with this privacy notice.

Links to Other Web Sites

This privacy notice does not cover the links within this site linking to other websites. Those sites are not governed by this privacy notice, and if you have questions about how a site uses your information, you’ll need to check that site’s privacy statement.

Cookies

Cookies are small text files that store information on your hard drive or browser, which means that we can recognise that you have visited our website.

They make it easier for you to maintain your preferences on our website.

A cookie often includes a randomly generated number which is stored on your device. Many cookies are automatically deleted after you finish using the website.

Use of Cookies

This website does not store any information that would, on its own, allow us to identify individual users of this service without their permission.

Any cookies that may be used on this website are used either solely on a per-session basis or to maintain user preferences. Cookies are not shared with any third parties.

Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third-party cookies. For example, in Internet Explorer, you can refuse all cookies by clicking Tools ⇒ Internet Options⇒ Privacy ⇒ Block all cookies, then use the sliding selector.

Blocking all cookies will, however, have a negative impact upon the usability of many websites, including this one.

Types of cookies that may be used during your visit to the website are listed below:

Third Party Embeds

The section below lets you control the privacy settings for third-party embeds on this site. We provide you with the choice to accept these third-party embeds or not. The checkboxes below show you all the embeds you have consented to so far. You can opt out any time by unchecking them and clicking the update button.

• YouTube
• Vimeo
• Facebook
• Twitter / X
• Google Maps
• Tracking Cookies

Changes to this Privacy Notice

We keep our privacy notice under regular review. This privacy notice was last updated on 25/01/2021.

How to contact us about your personal data or this privacy notice

If you have any questions about this privacy notice or about your personal data, please email us at info@rumpuspr.com

Rumpus Limited (“the Company”) is committed to the practice of responsible corporate behaviour.

Through its business practices, the Company seeks to protect and promote the human rights and basic freedoms of all its employees and agents.

Further, the Company is committed to protecting the rights of all of those whose work contributes to the success of the Company, including those employees and agents of suppliers to the Company.

The Company is also committed to eliminating bribery and corruption. It is essential that all employees and persons associated with the Company adhere to this policy and abstain from giving or receiving bribes of any form.

This policy is non-exhaustive, and all aspects of the Company’s business should be considered in the spirit of this policy.

Human Rights

The Company is vehemently opposed to the use of slavery in all forms; cruel, inhuman or degrading punishments; and any attempt to control or reduce freedom of thought, conscience and religion.

The Company will ensure that all of its employees, agents and contractors are entitled to their human rights as set out in the Universal Declaration of Human Rights and the Human Rights Act 1998.

The Company will not enter into any business arrangement with any person, company or organisation which fails to uphold the human rights of its workers or who breaches the human rights of those affected by the organisation’s activities.

Workers’ Rights

The Company is committed to complying with all relevant employment legislation and regulations. The Company regards such regulations and legislation as the minimum rather than the recommended standard.

No worker should be discriminated against based on age, gender, race, sexual orientation, religion or beliefs, gender reassignment, marital status or pregnancy. All workers should be treated equally. Workers with the same experience and qualifications should receive equal pay for equal work.

No worker should be prevented from joining or forming a staff association or trade union, nor should any worker suffer any detriment as a result of joining, or failing to join, any such organisation.

Workers should be aware of the terms and conditions of their employment or engagement from the outset. In particular, workers must be made aware of the wage that they receive, when and how it is to be paid, the hours that they must work and any legal limit which exists for their protection and any overtime provisions. Workers should also be allowed such annual leave, sick leave, maternity/paternity leave and such other leave as is granted by legislation as a minimum.

The Company does not accept any corporal punishment, harassment in any form, or bullying in any form.

Environmental Issues

The Company is committed to keeping the environmental impact of its activities to a minimum and has established an Environmental Policy to help achieve this aim. Copies of the Environmental Policy are available within our Employee Handbook.

As an absolute minimum, the Company will ensure that it meets all applicable environmental laws in whichever jurisdiction it may be operating.

Conflicts of Interest

The Company holds as fundamental to its success the trust and confidence of those with whom it deals, including clients, suppliers and employees. Conflicts of interest potentially undermine the relationship of the Company with its partners.

In order to help preserve and strengthen these relationships, the Company has developed a Corporate Hospitality and Gifts Policy, which provides rules and guidelines concerning the conduct of its officers and employees aimed at minimising the possibility of conflicts of interest and at avoiding risks associated with bribery and corruption. Copies of the Corporate Hospitality and Gifts Policy are available within the employee handbook.

All officers, employees and representatives of the Company are expected to act honestly and within the law.

Information and Confidentiality

Information received by employees, contractors or agents of the Company will not be used for any personal gain, nor will it be used for any purpose beyond that for which it was given.

The Company will at all times ensure that it complies with all applicable requirements of the Data Protection Legislation. “Data Protection Legislation” means (1) unless and until General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) is no longer directly applicable in the UK, the GDPR and any national implementing laws, regulations, and secondary legislation (as amended from time to time) in the UK and subsequently (2) any legislation which succeeds the GDPR.

Suppliers and Partners

The Company expects all suppliers and partners to work towards and uphold similar ethical and moral standards.

The Company will investigate the ethical record of potential new suppliers before entering into any agreement. Further, the Company reserves the right to request information from suppliers regarding the production and sources of goods supplied.

The Company reserves the right to withdraw from any agreement or other arrangement with any supplier or partner who is found to have acted in contravention of the spirit or principles of this Ethical Policy.

Bribery and Corruption

The Company is fundamentally opposed to any acts of bribery and the making of facilitation payments as defined by the Bribery Act 2010.

Employees and any other persons associated with the Company, such as agents, subsidiaries and business partners, are not permitted to either offer or receive any type of bribe and/or facilitation payment.

All employees are encouraged to report any suspicion of corruption or bribery within the Company in accordance with the Whistleblowing Policy available within the Employee Handbook.

Should any employee or associated person be in doubt when receiving or issuing gifts and hospitality, he/she must refer to the Gift and Hospitality Policy available within the Employee Handbook.

The Company uses its reasonable endeavours to implement the guiding principles on bribery management that are published, from time to time, by the Secretary of State in accordance with Section 9 of the Bribery Act 2010.

If an employee or associated person is found guilty of giving or receiving a bribe, he/she will be personally criminally liable and may be subject to disciplinary action.

Anyone found guilty of bribery will be responsible for bearing any related remedial costs such as losses, court fees or expenses.

Hospitality and Gifts Policy

The Company recognises that trust and confidence in the propriety of its activities are essential to its continuing success and growth. To foster the trust and confidence that clients, suppliers, workers and the community, in general, have in the Company, it is important that the Company, its employees and agents behave, and are seen to behave, appropriately and honestly at all times.

This Hospitality and Gifts Policy aims to:

• Protect the reputation of the Company;
• Protect employees from accusations of impropriety;
• Ensure that all clients and suppliers are dealt with on an equal basis;
• Avoid any potential conflicts between employees’ private interests and professional duties;
• Instil a strong anti-corruption culture in the Company and put in place a gift and hospitality monitoring process to further compliance with the Bribery Act 2010.

Employees are advised that notwithstanding anything contained herein, where there is any doubt over the permissibility or propriety of accepting a gift or hospitality offer, they should decline that offer. Nothing should be accepted which would bring the Company into disrepute.

This policy applies to the Company and to any associated persons as defined by the Bribery Act 2010.

Receiving Gifts

Save for gifts of low value and which are mere tokens (such as promotional pens, calendars and stationery), excluding money, employees of the Company are not permitted to accept any gifts from customers, suppliers or other third parties involved with the Company.

The Company recognises that there may be exceptional instances when refusing a gift will cause significant offence or embarrassment. In such instances, the gift may be accepted and subsequently donated to a charity of the Company’s choice.

Where practicable, any employee minded to accept a gift should first seek approval from their manager. If it is not practicable to gain prior approval, the accepting employee should inform their manager as soon as possible after receiving the gift.

Hospitality

“Corporate Hospitality”, for the purposes of this policy, is any form of accommodation, entertainment or other hospitality provided for an employee of the Company by a third party and which is extended to the employee solely or significantly due to his position as a representative of the Company.  This excludes the classes of hospitality particularised below.

For the purposes of this policy and for the sake of clarity, the following are not normally considered Corporate Hospitality and will not require any approval before acceptance:

Normal working lunches or refreshments provided during a business visit;

Hospitality extended to employees attending a Company-approved seminar, conference or other external event, provided that such hospitality is extended to all who are in attendance;

Free seminars, talks or workshops, provided that they are free to all in attendance and are not provided solely for employees of the Company.

All employees are required to obtain approval before accepting any form of Corporate Hospitality which is offered to them. Approval must be sought from their manager or, where the value of the Corporate Hospitality is likely to be over £50, from a Director.

An accurate record must be kept of all Corporate Hospitality offered to the Company or employees of the Company for entry on the Register. Any employee offered any form of Corporate Hospitality must record, as soon as is reasonably practicable:

A description of the hospitality offered;

• An estimation of the likely value of the hospitality;
• Whether it was rejected or accepted;
• If accepted, why it was accepted; and
• From whom prior approval was obtained.

Breach of this Policy

Compliance with this policy is essential to the protection of the Company’s reputation and that of its employees. Any employee or an associated person who is found to have acted in contravention of this policy or its principles may be subject to disciplinary action, including summary dismissal where the breach amounts to gross misconduct.

Any employee or any associated person (as defined by Section 8 of the Bribery Act 2010) found giving or receiving bribes or bribing a foreign official will face criminal charges under the provisions of the Bribery Act 2010. Anyone found guilty of bribery will be responsible for bearing any related remedial costs such as losses, court fees or expenses.

Anti-Bribery Policy

The Company is committed to ensuring that all our commercial dealings meet the highest professional standards. It would never be acceptable for anyone to accept or offer bribes in any business transaction.

Bribes may come in a variety of forms such as corporate hospitality, charitable donations and personal gifts, as well as money. Any employee being offered any of these must report this to the Director, who will advise how to manage the situation. Breaches of this rule will result in disciplinary action up to and including dismissal.

Introduction

Bribery and corruption remain major issues in world trade, despite the many dedicated efforts to prevent them. Our legal obligations are primarily governed by the Bribery Act 2010. That Act affects us, as a UK company, if bribery occurs anywhere in our business.

Corruption and bribery are very damaging to the societies in which they occur. They divert money and other resources from those who need them most and hinder economic and social development. They damage business, not least by increasing the cost of goods and services.

The Company runs its business with integrity and in an honest and ethical manner. All of us must work together to ensure that our business remains untainted by bribery or corruption. This policy is a crucial element of that effort. This policy has the full support of the Company’s board. However, the policy needs the full support of you, the Company’s staff, to make it work.

This policy sets out the steps all of us must take to prevent bribery and corruption in the business to comply with relevant legislation and the Company’s requirements.

What are bribery and corruption?

A ‘bribe’ is a financial or other advantage offered, promised, requested or given to induce a person to perform a relevant function or activity improperly, or to reward them for doing so. In this context, a ‘financial or other advantage’ is likely to include cash or cash equivalents, gifts, hospitality and entertainment, services, loans, preferential treatment in a tendering process, discounts, etc. The timing of the bribe is irrelevant, and payments made after the relevant event will still be caught, as will bribes that are given or received unknowingly. It is not necessary for the individual or organisation actually to receive any benefit as a result of the bribe.

‘Bribery’ includes offering, promising, giving, accepting or seeking a bribe.

‘Corruption’ is the misuse of office or power for private gain.

All forms of bribery and corruption are strictly prohibited. If any member of staff is unsure about whether a particular act constitutes bribery, they should raise it with their Manager.

Staff must not:

• give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received, or to reward any business received;
• accept any offer from a third party that you know, or suspect is made with the expectation that we will provide a business advantage for them or anyone else; and
• give or offer any payment (sometimes known as a ‘facilitation payment’) to a government official in any country to facilitate or speed up a routine or necessary procedure.

No person must threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

Who might be involved in bribery and in what circumstances?

Bribery and corruption might be committed by:

• the Company’s employees, officers or directors;
• anyone they authorise to do things on their behalf;
• the Company’s representatives and other third parties who act on its behalf;
• the Company’s suppliers; and
• even the Company’s customers (for example, a customer might try to induce one of the Company’s employees to give that customer more favourable terms).

Bribery can occur in both the public and private sectors. The person receiving the bribe is usually in a position to influence the award or the progress of business, often a government or other public official.

The legal position on bribery

Bribery and corruption are criminal offences in most countries where the Company does business. UK-incorporated companies, including the Company, are subject to the Bribery Act 2010. Under the Act, it is illegal:

• to pay or offer to pay a bribe;
• to receive or agree to receive a bribe;
• to bribe a foreign public official; and/or
• for a commercial organisation, to fail to have adequate procedures in place to prevent bribery.

It does not matter whether the bribery occurs in the UK or abroad. A corrupt act committed abroad may well result in a prosecution in the UK.

The Company’s position on bribery

Involvement in bribery and corruption exposes the Company to a criminal offence. It will also damage our reputation and the confidence of our clients, customers, suppliers and business partners.

The Company’s position is simple: the Company conducts its business to the highest legal and ethical standards. The Company will not be a party to corruption or bribery in any form. Such acts would damage the Company’s reputation and expose the Company, and its employees and representatives, to the risk of fines and imprisonment.

The Company takes a zero-tolerance approach to bribery and corruption by its people and its third-party representatives.

Bribery may be more widespread in some countries and business sectors than in others. In some cases, you may be told that unless the Company pays bribes, it will not win business or be able to complete contracts. That does not matter.

This ethical stance is good for our business and is non-negotiable.

What are the indicators of bribery and corruption?

Common indicators of bribery and corruption include those listed below, but there may well be others. Examples include:

Payments are for abnormal amounts or purposes (eg ‘commission’), or made in an unusual way (eg what would normally be a single payment is made in stages, through a bank account never previously used, and/or in a currency or via a country which has no connection with the transaction);

Process is bypassed for approval or sign-off of terms or submission of tender documents, payments, or other commercial matters; those whose job it is to monitor commercial processes may be prevented from or hindered in doing so;

• Individuals are secretive about certain matters or relationships and/or insist on dealing with particular customers or contacts personally; they may make trips at short notice without explanation, or have a more lavish lifestyle than expected;
• Decisions are taken for which there is no clear rationale; and/or
• Records are incomplete or missing.

Your responsibility

Everyone in the Company is responsible:

• for reading and being aware of the contents of this policy and complying with it;
• for keeping full and accurate records of all cases where bribery is suspected; and
• for reporting cases where the individual knows or has a reasonable suspicion that bribery has occurred or is likely to occur in the business.

We will not penalise anyone who loses business as a result of not engaging in bribery or corruption.

Corporate hospitality

Corporate hospitality that is proportionate and offered as part of building business relationships that are open and transparent and approved by a Director is permitted by this policy. Please see our corporate hospitality policy within the employee handbook for more information.

What to do if you think something is wrong

Each of us has a responsibility to speak out if we discover anything corrupt or otherwise improper occurring in relation to the business. The Company cannot maintain its integrity unless we do that. If you are offered a bribe or are asked to make one, or if you discover or suspect that any bribery or corruption has occurred or may occur, you must tell your Manager.

You must make your report as soon as reasonably practicable. You may be required to explain any delays.

Compliance with this policy

The Company takes compliance with this policy very seriously. Failure to comply puts both individuals and the Company at risk.

Individuals may commit a criminal offence if they fail to comply with this policy. The criminal law relating to bribery and corruption carries severe penalties.

Because of the importance of this policy, failure to comply with any requirement of it may lead to disciplinary action under our procedures, and this action may result in dismissal for gross misconduct.

Purchasing and Commissioning

The overriding principle is that all dealings with current and potential suppliers and service users are seen to be properly handled, with the application of high standards of objectivity, integrity and fairness.

The Company is involved in commissioning work and in tenders for contracts with other organisations. Unless the Managing Director has given specific permission, employees must not provide information, support or assistance to any Company or organisation tendering for work with them that would in any way enhance their chances of being successful in their bid.

Corporate Social Responsibility

Corporate Social Responsibility (CSR) is the concept whereby the Company integrates social and environmental concerns into their business operations and into their interaction with its stakeholders voluntarily. The Company is committed to adopting best practices in this area.

The Company is fully committed to the principle of CSR and intends that CSR should become embedded, where appropriate, into its policies and practices, to the benefit of staff, people we support, as well as the wider community.

The Company aims to be recognised as an organisation that is transparent and ethical in all its dealings as well as making a positive contribution to the community in which it operates. It is committed to the following core values in all aspects of its work, including the fulfilment of its social responsibility:

• Clear direction and strong leadership
• Customer focus
• Respect for people
• Open communication
• Working to deliver the best value
• Openness and transparency
• Equality
• Probity
• Development of positive working relationships with others
• Commitment to the highest ethical standards of service; and
• Valuing and harnessing the diversity of The Company staff.

CSR Strategies

The Company will seek to achieve corporate and social objectives by focusing on five strategic areas:

Equal Opportunities – maintaining and promoting our commitment to the fulfilment of and the promotion of equal opportunities.

Good Relations – The Company has developed and maintained good relations with other providers and professionals.

Workplace – addressing the needs and aspirations of staff through the continuing development of diversity, work-life balance and health and wellbeing initiatives.

Community Impact – encouraging and assisting staff to greater involvement in team/individual projects in support of the wider community.

Environment – further developing environmental management practices that minimise waste and maximise efficiencies.

Purchasing Principles

Adopting an environmentally friendly purchasing policy has 2 objectives:

• To ensure the Company purchases products which minimise damage to the environment;
• To persuade suppliers to offer products which minimise damage to the environment.

It is the Policy of the Company to purchase products and services which minimise damage to the environment and to inform suppliers of our policy.

Suggestions for implementing this policy include:

• Purchase of products made from recycled materials or derived from sustainable sources including:
• All paper products
• Wooden Furniture
• Purchase of products which minimise environmental pollution or damage including:
• Biodegradable cleaning products;
• Organic food;
• Avoiding genetically-modified food products;
• Avoiding unnecessary packaging;
• Opting for local producers and suppliers (reducing transportation).

The purpose of this policy is not to make perfect decisions, but to create a mindset that thinks about the issues and tries to make informed decisions.  It is recognised that price is also a factor, and many ‘environmentally friendly goods and services are more expensive than their industrialised counterparts.  Some are simply not up to the job and should therefore be avoided.

Public Interest Disclosure Policy (Whistle Blowing Policy)

We encourage an open culture in all our dealings with employees, Managers, and everyone with whom we come into contact. Effective and honest communication is essential if malpractice is to be effectively dealt with. The procedure below provides guidelines to all our employees, casual, temporary agency staff, freelancers, trainees, home workers and contractors, who feel they need to raise certain issues, in confidence.

The Public Interest Disclosure Act 1998 (commonly known as the ‘Whistle Blowing Act’) protects workers who raise legitimate concerns about specified matters from being dismissed by the Company or being subjected to detrimental treatment or victimised by either the Company or colleagues, provided certain criteria are met. Certain kinds of disclosures qualify for protection, and these are set out below. These are disclosures of information which a worker reasonably believes are made in the public interest. They tend to show one or more of the following relevant failures are either happening now, took place in the past, or are likely to happen in the future:

• A criminal offence has been committed, including offences such as theft, fraud or acts of bribery
• A person has failed, is failing or is likely to fail to comply with a legal obligation which they are subject to
• A miscarriage of justice
• A danger to the health and safety of any individual

Damage to the environment

Deliberate covering up of information tending to show any of the above five matters.

The procedure is not a substitute for the Disciplinary and Grievance Policy and is not a channel for employees to raise matters in relation to their terms and conditions of employment. The procedure allows individuals to have their concerns treated in confidence.

Your protection

If you raise a genuine concern, you will not be at risk of damaging your position as a result. Provided you are acting in the public interest, it does not matter whether or not your concern proves to be well-founded. You must, however, make your complaint to the right person and in the right way as detailed in this Policy. The Company does not, of course, extend this assurance to someone who acts from an improper motive and raises a matter they know to be untrue.

Your confidence

The Company will not tolerate the victimisation of anyone raising a genuine concern and anyone responsible for such conduct will be subject to disciplinary action. You may decide that you want to raise a concern in confidence. Therefore, if you ask for your identity to be protected, it will not be disclosed without your agreement. If it is not possible to deal with the concern without revealing your identity (for instance because your evidence is needed in court or a disciplinary hearing), there will be a discussion as to whether and how we can proceed. This Policy does not cover the situation where information about malpractice is received anonymously. However, discretion will be used in the investigation of such information.

How to raise your concern

Stage 1: Internal Line Management

If you have a concern about malpractice, we hope you will feel able to raise it first with your line manager or a more senior manager. This should be done in writing. It will help if you state the facts of the matter clearly. You can outline how you would like it to be investigated. If you have a direct or personal interest in the matter, you should also tell us at this stage.

Stage 2: Alternative contacts

If you feel unable to raise the matter with someone in your Line Management, for whatever reason, please speak to a director.

If you want to raise the matter in confidence, we will ensure that practical measures are put in place to protect your identity. We will contact you by the most secure means. We will not disclose your identity without your agreement unless we are required to do so by law.

Once you have reported your concern, the Company will investigate it to assess initially what action should be taken. If your concern falls more appropriately within other policies, we will tell you. A Manager will be asked to carry out the investigation.

The disclosure will be treated seriously and promptly investigated. As part of the process, the worker will be interviewed and asked to provide a written statement.

Once the Company has finalised the investigation, any necessary action will be taken.

While the purpose of this Policy is to enable us to investigate possible malpractice and take appropriate steps to deal with it, we will give you as much feedback as we properly can. If requested, we will confirm our response to you in writing. Please note, however, that we may not be able to tell you the precise action we take where this would infringe a duty of confidentiality owed by us to someone else.

If you are dissatisfied

If you are unhappy with the Company’s response, you may then go to the proper authority. However, we do ask that matters are reported to the Company in the first instance. While we cannot guarantee that we will respond to all matters in the way that you might wish, the matter will be handled fairly and properly. By using this Policy, you will help us to achieve this.

We commit to honesty in our marketing.

We pledge to:

• Never use dishonest marketing tactics for our own or client marketing campaigns, including:
• False advertising: exaggerating the values and benefits of our services
• Fake or overly doctored reviews and testimonials
• Inflated analytics or results when creating messaging for clients or within our advertising.
• Only use information in our marketing and communications that is representative of a client’s overall impact and does not present misleading data.
• Provide accurate descriptions of the services we provide and use appropriate language and words to reflect them.

We commit to rejecting impact washing

Impact washing is when impact-focused claims are made by a company without any demonstrable positive social or environmental impact.

We commit to rejecting the practice of impact washing. We will not exaggerate our positive impact to gain a marketing advantage or distract from any socially or environmentally negative impacts.

We pledge that:

• We will not inflate numbers, manipulate data, or mislead audiences with stories that aren’t reflective of the overall outcomes of our projects.
• We will not make unrealistic claims about expected results.
• We only share stories and create impact initiatives that are centred on our mission, to enable companies to prosper by helping them become a force for good, and not purely for marketing benefits.
• Our campaigns are fully honest and transparent about the social and environmental impacts of our or our client’s work.
• We will review marketing and communications strategies and tactics to ensure that they are not engaging in impact-washing.
• We commit to cultural sensitivity in our campaign creatives

Many marketing campaigns and messages have the potential to be insensitive. It takes a combination of self-awareness and the inclusion of others in the creative process to avoid marketing campaigns that are insensitive.

Our marketing projects will avoid the saviour complex. Sometimes well-intentioned people target a perceived need for support without including and empowering the affected community. They may use their access to resources to provide a solution solely from their external position of privilege. This approach can be characterised as a saviour complex, and resulting communications, solutions, and power dynamics are often problematic and reinforce systems of oppression.

Dignity vs focusing on the problem

In our communications, we choose how to represent people. Typically, people who have barriers in their lives are in the best position to remove those barriers. The process of dignification, deep understanding, and empowerment are the first steps toward solving key social issues. It is also important to recognise and understand the social and economic systems that lead to the issue in the first place. Any complex issue likely has multiple causes and multiple potential solutions, and it’s important, as marketers for organisations that are trying to address any social or environmental issue, that we humble ourselves and commit to exploring various perspectives and options for how to build campaigns aimed at promoting products or services as solutions to long-standing issues.

Using images of people in need, especially stereotypical images, to elicit an emotional response and drive engagement and/or donations from the audience is problematic. This approach all too often misrepresents or oversimplifies issues while dishonouring real people and communities that need support. While it may be tempting to take this approach, it can easily lead to insensitive campaigns and messages that may disempower the communities that we are striving to empower.

We pledge to:

• Take steps to avoid any exploitation, appropriation, or stereotyping of underrepresented or historically oppressed people or groups within marketing content.
• Seek out feedback on the appropriateness and sensitivity of marketing content. This looks different for different projects but often involves working with the client to seek stakeholder input and engaging the target audience via surveys, focus groups, or interviews.
• Ongoing internal training to increase awareness of cultural sensitivity and inclusiveness.

We commit to permission-based email marketing. This is marketing where the recipient of the marketing messages provides permission to send them marketing materials.

We pledge to focus our email marketing on:

• Creating value within any free content (including videos, blogs, online resources, social media posts, etc.)
• Being GDPR compliant
• Maintaining the trust of email lists by continuing to offer value and restricting messaging to content related to the original opt-in intent.
• We commit to ethical digital advertising

Aside from considering the accuracy and honesty of the content, we must also consider the ethics of the targeting approach. Digital advertising brings its own unique set of ethical issues related to data privacy. Facebook, Google, and many other digital media companies have developed sophisticated tracking technologies to understand, profile, track, and target users online so that their paying advertisers can reach their exact target audience via their digital advertising products and services. This kind of granular targeting often comes at the cost of individual users’ privacy. As consumer attitudes and technologies change, the ethical considerations that surround digital advertising are rapidly evolving. It is highly likely that the line between what is both legal and ethically acceptable will shift many times over the short and long term.

Our approach to ethical advertising includes the following considerations:

False advertising: If an advertisement makes untrue claims about a product or service or clearly misrepresents what is being offered, then it is false advertising, which is clearly an unethical marketing tactic

Issues with Advertorial Advertising

It is important that an online user can tell what is paid advertising vs what is editorial content. Advertorial content is content that looks like unbiased editorial/earned media but is actually paid to advertise. This type of content can take place in written articles, social media posts, written reviews, or videos. Influencer marketing often relies on the process of well-connected social influencers promoting products or services to their audiences, often through content that would be considered advertorial if the influencer is not transparent that the content is a paid promotion. While advertorial content may be seen by some as an ethical grey area, it is increasingly becoming clear that misleading users into believing that a brand mention is based on editorial merit alone, when in fact the placement was paid for by the brand, is an unethical marketing tactic by both the publisher and brand buying the paid content.

Pop-ups, pop-unders and modal windows: Pop-ups or pop-unders (that create new tabs or windows behind the main browser window) are now widely considered unethical marketing tactics. They often offer misleading statistics about how many people see their content, and few users actually engage with this type of content. The modal window is a term for using similar techniques within your own website where the pop-up is part of your own web page. Modal windows are often used for contact forms, email signups and other strategies. When properly implemented, modal windows can be helpful for the user and very effective for marketing; however, when overused, they can become annoying and can degrade the user’s experience of your website.

Examples of best practices for modal window use:

• Use them in ways that offer clear value
• Limit how often they are used; allow people to opt out of modal windows
• Make it easy to close them
• If a user closes a modal window, save that info so that they don’t see them repeatedly
• If a user completes a modal window for an opt-in, then you don’t need to show that user the window again.

We commit to ethical search engine optimisation (SEO)

Search engines use algorithms to determine what content to show at the top. In the world of SEO and content marketing, any tactics that are considered manipulative or unethical are typically referred to as “black hat” tactics. On the opposite end of this spectrum, you’ll find ethical or “white hat” SEO tactics based on providing valuable and useful content that aligns with what users and search algorithms are looking for.

Through the use of white hat SEO, we will provide valuable and useful content that aligns with what users and search algorithms are looking for.

We practise and encourage the following best practices for white hat SEO and content marketing:

• Link building: Create valuable content that people will want to link to
• Using PR and aligned partnerships to build links.
• Proper use of redirects to help users find the right content.
• Creating helpful, well-branded 404 pages with useful navigation
• Put the user first, focus on value, and create content that aligns with our mission.

Black hat SEO tactics that we avoid and discourage:

• Purchasing links – Paying for links from other websites. Links should be built organically out of merit and from real relationships and partnerships.
• Hidden content and links – Intentionally hiding content or links so that only the search engines can see them.
• Keyword stuffing, over-optimisation – There is a fine line between manually optimising content for SEO best practices (white hat on-page optimisation) and over-optimisation, which can also be called keyword stuffing. It takes experience and a deep understanding of the latest algorithms to learn where this line is. As the algorithm changes, the line may shift over time.
• Misdirection – Unethical redirects: Cloaking and doorway pages. There are a variety of shady redirection schemes used in black hat SEO. These typically involve redirecting people away from long-form content into pages that are more focused on conversions/sales, affiliate marketing, or paid advertising. In these cases, the content that appealed to the search engine algorithm, which resulted in the high organic ranking, is not what the user sees after they click the link.

We commit to updating these practices as the industry evolves.

We expect ethical marketing practices to continue to evolve along with the technologies marketers use to discover, reach, and engage audiences. The line that separates ethical from unethical marketing practices can shift rapidly as major online platforms such as Google, Facebook, and other search and social applications roll out updates and new options for data-driven targeting. We will continue to monitor the state of the field across different marketing channels and tactics and update our practices accordingly.

At Rumpus, we are committed to the ethical and responsible use of AI within our operations. We view AI as a valuable tool to complement and enhance our existing processes rather than replacing or taking a substantive role in our content creation. To uphold these principles and ensure transparency in our AI-related activities, we pledge:

Transparency: We will maintain transparency with our clients regarding the AI tools we employ, should they wish to be informed. Disclosure methods can vary depending on the situation, encompassing written communication or verbal disclosure. Furthermore, our employees, vendors and influencers will disclose the use of generative AI tools as part of the content drafting or creation process.

Data Privacy: We are committed to safeguarding the privacy of client data. We commit to refraining from utilising generative AI tools to produce confidential content. In such cases, we may employ proxy and anonymous company and personal information to preserve privacy.

Accuracy: We diligently review and verify any data generated by generative AI tools. We ascertain their authenticity by cross-referencing them with the original sources. Furthermore, we rigorously scan AI-generated content to prevent unintended instances of plagiarism, copyright violations, or trademark infringements.

Diversity & Inclusion: We actively promote diversity and inclusion by acknowledging the potential biases embedded in AI-generated prompts and outputs. We utilise our B LONG EDI framework to detect and rectify biases, ensuring they are not propagated externally.

AI Imagery: When employing generative AI images as any creative component of a client campaign, we will source them from outlets that do not pose a risk of copyright infringement, thereby ensuring the client’s or any other party’s ownership rights are not compromised.

Responsibility: We firmly commit to refraining from using generative AI to create or propagate deepfakes, misinformation, or disinformation. We respect and acknowledge the crucial role of PR agencies in society and act in accordance with this understanding.

Environmental Mission statement

At Rumpus PR we recognise that the environment is important to our business, our staff and our clients. We recognise our responsibility to manage our environmental impacts carefully. We are committed to reducing our environmental impact and continually improving our environmental performance as an integral part of our business strategy and operating methods, with regular review points. We will encourage clients, suppliers and other contacts to do the same.

Policy aims

We endeavour to:

• Incorporate environmental considerations into our business decisions.
• Continually improve and monitor our own environmental performance.
• Promote environmental awareness among our staff, clients and partners.

Policy priorities

1. Carbon footprint

We will measure our carbon footprint, seek to achieve annual reductions in our emissions and publicly report our progress annually.

2. Energy, water & waste

We will continue to seek ways of reducing the amount of energy and water used in our premises and encourage and facilitate staff to do the same in their home offices.

We will continue to reduce our use of paper, and maximise recycling of all waste arising from our operations.

3. Transportation

We will continue to reduce the need to travel through applying a hybrid working policy and making extensive use of video-conferencing.

We will promote the use of more sustainable forms of transport to our staff, and facilitate their use.

4. Purchasing

We will take account of environmental considerations in the purchasing of all goods and services.

We will develop and adopt an Environmentally Preferable Purchasing Policy.

5. Company administration

We will prioritise environmental considerations in our key business decisions.

We will promote our commitment to environmental protection to all of our clients and suppliers.

Our Environmental Management System

We have developed an Environmental Action Plan to ensure we meet the requirements of this policy. The Environmental Action Plan, together with this policy, comprises our Environmental Management System (EMS). Our EMS is independently certified by Green Small Business. Our certification is maintained through an annual audit carried out independently by Green Small Business.

We will update this policy at least annually.