CiRO

CiRO Policies

ANTI BRIBERY POLICY

One of CiRO’s core values is to uphold responsible and fair business practices.

We are committed to promoting and maintaining the highest level of ethical standards in relation to all of our business activities. Our reputation for maintaining lawful business practices is of paramount importance and this Policy is designed to preserve these values.

CiRO therefore has a zero tolerance policy towards bribery and corruption and is committed to acting fairly and with integrity in all of its business dealings and relationships and implementing and enforcing effective systems to counter bribery. This Policy sets out CiRO’s position on any form of bribery and corruption and provides guidelines aimed at:

  • Ensuring compliance with anti-bribery laws, rules and regulations, not just within the UK but in any other country within which CiRO may carry out its business or in relation to which its business may be connected.
  • Enabling employees and persons associated with CiRO to understand the risks associated with bribery and to encourage them to be vigilant and effectively recognise, prevent and report any wrongdoing, whether by themselves or others.
  • Providing suitable and secure reporting and communication channels and ensuring that any information that is reported is properly and effectively dealt with • Creating and maintaining a rigorous and effective framework for dealing with any suspected instances of bribery or corruption.

This Policy applies to all permanent and temporary employees of CiRO (including any of its intermediaries, subsidiaries or associated companies). It also applies to any individual or corporate entity associated with CiRO or who performs functions in relation to, or for and on behalf of CiRO, including, but not limited to, directors, partners, agency workers, casual workers, contractors, consultants, seconded staff, agents, suppliers and sponsors (“associated persons”). All employees and associated persons are expected to adhere to the principles set out in this Policy.

Legal obligations

The UK legislation on which this Policy is based is the Bribery Act 2010 and it applies to CiRO’s conduct both in the UK and abroad. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

It is an offence in the UK to:

  • Offer, promise or give a financial or other advantage to another person (i.e. bribe a person), whether within the UK or abroad, with the intention of inducing or rewarding improper conduct
  • Request, agree to receive or accept a financial or other advantage (i.e. receive a bribe) for or in relation to improper conduct.
  • Bribe a foreign public official.

You can be held personally liable for any such offence. It is also an offence in the UK for an employee or an associated person to bribe another person in the course of doing business intending either to obtain or retain business, or to obtain or retain an advantage in the conduct of business, for the Company. CiRO can be liable for this offence where it has failed to prevent such bribery by associated persons. As well as an unlimited fine, it could suffer substantial reputational damage.

Policy statement

All employees and associated persons are required to:

  • Comply with any anti-bribery and anti-corruption legislation that applies in any jurisdiction in any part of the world in which they might be expected to conduct business.
  • Act honestly, responsibly and with integrity.
  • Safeguard and uphold CiRO’s core values by operating in an ethical, professional and lawful manner at all times.
  • Bribery of any kind is strictly prohibited. Under no circumstances should any provision be made, money set aside or accounts created for the purposes of facilitating the payment or receipt of a bribe.

CiRO recognises that industry practices may vary from country to country or from culture to culture. What is considered unacceptable in one place may be normal or usual practice in another. Nevertheless, a strict adherence to the guidelines set out in this Policy is expected of all employees and associated persons at all times. If in doubt as to what might amount to bribery or what might constitute a breach of this Policy, refer the matter to CiRO’s Anti-Corruption Officer.

The giving of business gifts to clients, customers, contractors and suppliers is not prohibited provided the following requirements are met:

  • The gift is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage.
  • It complies with local laws.
  • It is given in CiRO’s name, not in the giver’s personal name.
  • It does not include cash or a cash equivalent (such as gift vouchers.
  • It is of an appropriate and reasonable type and value and given at an appropriate time.
  • It is given openly, not secretly.
  • It is approved in advance by a Senior Partner of the Company.

In summary, it is not acceptable to give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given, or to accept a payment, gift or hospitality from a third party that you know or suspect is offered or provided with the expectation that it will obtain a business advantage for them.

Any payment or gift to a public official or other person to secure or accelerate the prompt or proper performance of a routine government procedure or process, otherwise known as a “facilitation payment”, is also strictly prohibited. Facilitation payments are not commonly paid in the UK but they are common in some other jurisdictions.

Responsibilities and reporting procedure

It is the contractual duty and responsibility of all employees and associated persons to take whatever reasonable steps are necessary to ensure compliance with this Policy and to prevent, detect and report any suspected bribery or corruption. You must immediately disclose to CiRO any knowledge or suspicion you may have that you, or any other employee or associated person, has plans to offer, promise or give a bribe or to request, agree to receive or accept a bribe in connection with the business of the Company. For the avoidance of doubt, this includes reporting your own wrongdoing. The duty to prevent, detect and report any incident of bribery and any potential risks rests not only with the Senior Partners of CiRO but equally to all employees and associated persons. CiRO encourages all employees and associated persons to be vigilant and to report any unlawful conduct, suspicions or concerns promptly and without undue delay so that investigation may proceed and any action can be taken expeditiously. In the event that you wish to report an instance or suspected instance of bribery, you should contact a Senior Partner. Confidentiality will be maintained during the investigation to the extent that this is practical and appropriate in the circumstances.

CiRO is committed to taking appropriate action against bribery and corruption. This could include either reporting the matter to an appropriate external government department, regulatory agency or the police and/or taking internal disciplinary action against relevant employees and/or terminating contracts with associated persons.

CiRO will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken. It is also committed to ensuring nobody suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or corruption offence has taken place or may take place in the future.

Record keeping

All accounts, receipts, invoices and other documents and records relating to dealings with third parties must be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off the record” to facilitate or conceal improper payments.

Sanctions for breach

A breach of any of the provisions of this Policy will constitute a disciplinary offence and will be dealt with in accordance with CiRO’s disciplinary procedure. Depending on the gravity of the offence, it may be treated as gross misconduct and could render the employee liable to summary dismissal. As far as associated persons are concerned, a breach of this Policy could lead to the suspension or termination of any relevant contract, sub-contract or other agreement.

Monitoring compliance

CiRO’s Anti-Corruption Officer has lead responsibility for ensuring compliance with this Policy and will review its contents on a regular basis. They will be responsible for monitoring its effectiveness and will provide regular reports in this regard to the directors of CiRO who have overall responsibility for ensuring this Policy complies with CiRO’s legal and ethical obligations.

Training

CiRO will provide training to all employees to help them understand their duties and responsibilities under this Policy.

CiRO’s zero tolerance approach to bribery will also be communicated to all business partners at the outset of the business relationship with them and as appropriate thereafter.

PRIVACY POLICY

CiRO has created this security & privacy policy in order to demonstrate and communicate its commitment to conducting business in accordance with the highest legal and ethical standards and appropriate internal controls.

As part of the contact form used on this site, we request some private information which allows users to be contacted (like name, email address, and telephone number). This information is used to provide information to those who enquire about our products and services. This information is also used to get in touch with customers when necessary.

No personal information will be disclosed to third parties without the individual’s permission. However CiRO may share personal information when we are compelled to do so by law or in terms of a court order or if it is necessary to protect our rights.

CiRO does not currently capture information regarding the specific activities of any particular user. It does, however, produce reports which allow us to view activity in anonymous aggregated form. The only personal information we currently capture has been specifically submitted to us through the contact request form.

CiRO is not responsible for the security or privacy practices of, or the content of, sites other than CiRO LLP and its subsidiaries. We recommend that you always read the privacy and security statements on any websites. Our site is protected with a variety of security measures such as change control procedures, passwords, and physical access controls. We also employ a variety of other mechanisms to ensure that data you provide is not lost, misused, or altered inappropriately.

These controls include data confidentiality policies and regular database backups. If you wish to remove your name and related information from our database, we will promptly take action to comply with your written request for removal.

We reserve the right to amend this privacy and security statement at any time. All amendments to this privacy and security statement will be posted on the website. Unless otherwise stated, the current version shall supersede and replace all previous versions of this privacy and security statement.

If you have any questions about this privacy and security statement, or have any other concerns of the practices of CiRO, please email us on info@ciro-global.com.

DATA PROTECTION POLICY

Data Protection Act (DPA) 1998:

The Data Protection Act regulates how personal information is used and protects against misuse of personal details. This Act of Parliament also restricts and access to much information held specifically on databases and on files and fenders much information routinely available in other jurisdictions illegal. It is imperative that professional investigators are well versed in the DPA and act within its confines.

Data Protection Act (DPA) Registration:

CiRO LLP is registered under the Data Protection Act with The Ministry of Justice's Information Commissioner's Office (ICO). Registration number: Z3129387.

Data Privacy & Confidentiality Policy:

CiRO LLP protects the identifiable information of all online visitors and customer as follows:

Site Disclosure

CiRO LLP will not sell, trade, or disclose to third parties any client identifiable information derived from a visit, enquiry, or any legal use of this web site; this non-disclosure is including client name(s) and address (-es) and any other personally identifiable information, without the consent of the client (except as required by a court demand, a search warrant, or other legal process, or in an extreme case of imminent physical harm to the client or others being reasonably perceived).

Business Disclosure

CiRO LLP will not discuss, or communicate with any individual or individuals, existing client or third parties, details of any enquiries, discussions, negotiations, agreements or contracts made between any existing or potential clients and CiRO LLP without prior written permission of the client/customer (except as required by a court subpoena, a search warrant, or other legal process, or in an extreme case of imminent physical harm to the client or others being reasonably perceived).

Confidentiality

The Partners, Associates, consultants and officers of CiRO LLP believe that they and their clients have a reasonable right to privacy, and will do all in their power to protect that privacy, to the extent of the law.

Compliance

Data Protection Compliance Statement.

This is a statement of Data Protection Compliance adopted by CiRO LLP.

CiRO LLP needs to collect and use certain types of information about people with whom it deals in order to operate. These include current, past and prospective employees, suppliers, clients/customers, and others with whom it communicates. In addition, it may occasionally be required by law to collect and use certain types of information of this kind to comply with the requirements of government departments for business data, for example. This personal information must be dealt with properly, however it is collected, recorded and used whether on paper, in a computer, or recorded on other material and there are safeguards to ensure that this is stored in accordance with the Data Protection Act 1998.

We regard the lawful and correct treatment of personal information by CiRO LLP as very important to successful operations, and to maintaining confidence between those with whom we deal and ourselves. We ensure that our organisation treats personal information lawfully and correctly.

To this end we fully endorse and adhere to the Principles of Data Protection, as enumerated in the Data Protection Act 1998.

Specifically, the Principles require that personal information:

Shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met;

Shall be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes;

Shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are processed;

Shall be accurate and, where necessary, kept up to date;

Shall not be kept for longer than is necessary for that purpose or those purposes;

Shall be processed in accordance with the rights of data subjects under the Act;

Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.

Information will not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.

Therefore, CiRO LLP will, through appropriate management, strict application of criteria and controls:

Observe fully conditions regarding the fair collection and use of information;

Meet its legal obligations to specify the purposes for which information is used;

Collect and process appropriate information, and only to the extent that it is needed to fulfil operational needs or to comply with any legal requirements;

Ensure the quality of information used;

Apply strict checks to determine the length of time information is held;

Ensure that the rights of people about whom information is held, are able to be fully exercised under the Act. (These include: the right to be informed that processing is being undertaken, the right of access to one's personal information, the right to prevent processing in certain circumstances and the right to correct, rectify, block or erase information which is regarded as wrong information.);

Take appropriate technical and organisational security measures to safeguard personal information;

Ensure that personal information is not transferred abroad without suitable safeguards.

In addition, CiRO LLP will ensure that:

There is someone with specific responsibility for data protection in the organisation. (Currently, the nominated person is Senior Partner Brad Vearncombe);

Everyone managing and handling personal information understands that they are contractually responsible for following good data protection practice;

Everyone managing and handling personal information is appropriately trained to do so;

Everyone managing and handling personal information is appropriately supervised;

Anybody wanting to make enquiries about handling personal information knows what to do;

Queries about handling personal information are promptly and courteously dealt with; Methods of handling personal information are clearly described;

A regular review and audit is made of the way personal information is managed;

Methods of handling personal information are regularly assessed and evaluated;

Performance with handling personal information is regularly assessed and evaluated.

COOKIES POLICY

Our website uses cookies. By using our website you are agreeing to this policy and you consent to our use of cookies in accordance with the terms of this policy.

Cookies are files, often including unique identifiers, that are sent by web servers to web browsers, and which may then be sent back to the server each time the browser requests a page from the server.

Cookies can be used by web servers to identity and track users as they navigate different pages on a website, and to identify users returning to a website.

Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

We use session cookies on this website, which are third party session identifiers by our website content management system. We will send you a cookie called PHPSESSID. This records your session with our web host and is not used in any other manner.

Cookies do not contain any information that personally identifies you, but personal information that we store about you may be linked, by us, to the information stored in and obtained from cookies.

In addition, we use Google Analytics, through our service provider to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google's privacy policy is available at: http:// www.google.com/privacypolicy.html.

We may use the information we obtain from your use of our cookies for the following purposes:

  • To recognise your computer when you visit our website
  • To track you as you navigate our website
  • To analyse the use of our website
  • To improve the website’s usability

Most browsers allow you to refuse to accept cookies. For example:

  • in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector;
  • in Firefox you can block all cookies by clicking “Tools”, “Options”, and un-checking “Accept cookies from sites” in the “Privacy” box.

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

You can also delete cookies already stored on your computer:

  • in Internet Explorer, you must manually delete cookie files
  • in Firefox, you can delete cookies by, first ensuring that cookies are to be deleted when you “clear private data” (this setting can be changed by clicking “Tools”, “Options” and “Settings” in the “Private Data” box) and then clicking “Clear private data” in the “Tools” menu

Obviously, doing this may have a negative impact on the usability of many websites.

This website is owned and operated by CiRO LLP.

If you have any questions about our cookies or this Cookies Policy, please contact us by email at admin@ciro-global.com.

LEGAL DISCLAIMER

This website contains general information about our activities. The information is not advice, and should not be treated as such.

Any information on this website is provided without any representations or warranties express or implied. We make no representations or warranties in relation to the legal information on this website.

Without prejudice to the generality of the foregoing paragraph, we do not warrant that:

  • The information on this website will be constantly available, or available at all; or
  • The information on this website is complete, true, accurate, up-to-date, or nonmisleading

You must not rely on the information on this website as an alternative to legal advice from your lawyer or other professional legal services provider. If you have any specific questions about any matter you should consult your lawyer or other professional legal services provider. You should never delay seeking legal advice, disregard legal advice, or commence or discontinue any legal action because of information on this website.

Nothing in this legal disclaimer will:

  • Limit or exclude our liability for death or personal injury resulting from negligence
  • Limit or exclude our liability for fraud or fraudulent misrepresentation
  • Limit any of our liabilities in any way that is not permitted under applicable law; or
  • Exclude any of our liabilities that may not be excluded under applicable law
LINKING POLICY

We welcome links to this website; made in accordance with the terms of this linking policy.

By using this website you agree to be bound by the terms and conditions of this linking policy.

Links pointing to this website should not be misleading.

Appropriate link text should be always be used.

From time to time we may update the URL structure of our website, and unless we agree in writing otherwise, all links should point to www.ciro-global.com.

  • You must not use our logo to link to this website (or otherwise) without our express written permission
  • You must not link to this website using any inline linking technique
  • You must not frame the content of this website or use any similar technology in relation to the content of this website

This website does not include links to other websites owned and operated by third parties.

You agree that, should we request the deletion of a link to our website that is within your control, you will delete the link promptly.

We may amend this linking policy at any time by publishing a new version on this website.

Should you have any questions about this linking policy, please contact us at admin@ciro-global.com.

ANTI-SPAM POLICY

In the context of electronic messaging, spam refers to unsolicited, bulk or indiscriminate messages, typically sent for a commercial purpose.

We have a zero-tolerance spam policy.

Our messaging systems automatically scan all incoming email messages, and filter-out messages that appear to be spam. No message filtering system is entirely accurate, and from time to time legitimate messages will be filtered-out by our systems. If you believe this has happened to a message you have sent, please advise the message recipient by another means.

You can reduce the risk of a message being caught by the spam filters by sending the message in plain text (i.e. no HTML), removing any attachments, and ensuring that your messages are scanned for malware before dispatch.

Anti-spam law restricts the sending of unsolicited marketing emails (‘spam’) to individual subscribers. Unsolicited emails can still be sent to corporate subscribers if they are relevant to their work. In the unlikely event that you receive any message from us or sent using our systems that may be considered to be spam, please contact us on spam@ciroglobal. com.

Anti-spam law is enforced by the Information Commissioner and breaches can lead to a fine of up to £5,000. There is also civil liability to anyone who suffers damage as a result of the breach. The rules are in the Privacy and Electronic Communications (EC Directive) Regulations 2003. The regulations don't specifically deal with the worldwide problem of spam, and only cover emails sent from within the EU. There are other country specific regulations which will be adhered to when sending emails outside of this jurisdiction.

Definitions

‘Solicited’ and ‘unsolicited’ are not defined, but solicited emails are emails that recipients specifically ask us to send them. An unsolicited email is any other email.

A ‘marketing’ email is not defined by the law either, but it will include any email promoting our goods and services.

As a Limited Liability Partnership we are defined as a ‘corporate subscriber’.

The rules for corporate subscribers

We can ‘cold email’ an unsolicited, direct marketing email to a corporate subscriber.

This is permitted if the email is work-related (e.g. promoting our services to a similar business line) but not if it is personal.

Our policy is to market our services to legitimate businesses that are likely to utilise our services provided:

A work email address will be used, although a named employee, the email is being sent to the company - the ‘corporate subscriber’ - and no restrictions apply.

The rules for individual subscribers

If you specifically consent (‘opt-in’) to receiving emails, by request or other means we can send you direct marketing emails.

Opt-in is temporary

If you, as an individual subscriber, opt-in; your consent is only given ‘for the time being’. However, we will assume your consent remains valid until there is a good reason for us to consider otherwise.

Third party advertising consent

We do not allow third parties to advertise in our emails.

There are circumstances in which we can treat an individual subscriber as having consented to receiving emails from us, even though you haven’t specifically done so. We can send direct marketing emails to individual subscribers on the basis of the following points:

Your email address was obtained by us in ‘the course of the sale or negotiations for the sale of a product or service’ and allowed your email address to be recorded for future marketing use.

The direct marketing is in respect of our ‘similar products and services only’ You have been given a simple means of refusing and the use of your contact details for the purposes of such direct marketing, at the time that the details were initially collected.

You are given the opportunity to opt out in every email.

Rules applying to all CiRO emails

All direct marketing emails, whether to corporate subscribers or individuals, and whether unsolicited or solicited, will:

Make our identity clear (We will use the corporate signature)

Provide our email address to which ‘unsubscribe’ messages may be sent.

Existing emailing lists

By concession, the Information Commissioner has said that he will not apply the law to ‘legacy lists’. This means:

Email addresses which we have used within the last 12 months

Or addresses which we have collected in compliance with the law at the time

Or if you have not told us to stop emailing you.

The anti-spam rules specifically say that they do not affect any obligations in relation to personal data under the Data Protection Act 1988.

Under that Act individuals (as opposed to businesses) can prevent us from processing ‘personal data’ without their consent. See our Data Protection Policy. Personal data is data only relating to a living individual (but not companies). We may amend this anti-spam policy at any time. Should you have any questions about this anti-spam policy, please contact us at admin@ciro-global.com.

ENVIRONMENTAL POLICY

CiRO LLP recognises that it has a responsibility to the environment beyond legal and regulatory requirements. 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 customers, suppliers and other stakeholders to do the same.

Key Policy Aims

We endeavour to:

  • Comply with and exceed all relevant regulatory requirements
  • Continually improve and monitor environmental performance
  • Continually improve and reduce environmental impacts<.
  • Incorporate environmental factors into business decisions
  • Increase employee awareness and training

Method

Paper

  • We will minimise the use of paper in the office
  • We will reduce packaging as much as possible
  • We will seek to buy recycled and recyclable paper products
  • We will reuse and recycle all paper where possible

Energy and Water

  • We will seek to reduce the amount of energy used as much as possible
  • Lights and electrical equipment will be switched off when not in use
  • Heating will be adjusted with energy consumption in mind
  • The energy consumption and efficiency of new products will be taken into account when purchasing

Office Supplies

  • We will evaluate if the need can be met in another way
  • We will evaluate if renting/sharing is an option before purchasing equipment
  • We will evaluate the environmental impact of any new products we intend to purchase
  • We will seek to buy more environmentally friendly and efficient products
  • We will re-use and recycle everything we are able to

Transportation

  • We will reduce the need to travel, restricting to necessity trips only
  • We will promote the use of travel alternatives such as e-mail or video/phone conferencing
  • We will make additional efforts to accommodate the needs of those using public transport or bicycles
  • We will use 'greener' vehicles and maintain them rigorously

Maintenance and Cleaning

  • Cleaning materials will be as environmentally friendly as possible
  • Materials used in office refurbishment will be as environmentally friendly as possible
  • We will only use licensed and appropriate organisations to dispose of waste

Monitoring and Improvement

  • We will comply with and exceed all relevant regulatory requirements
  • We will continually improve and monitor environmental performance
  • We will continually improve and reduce environmental impacts
  • We will incorporate environmental factors into business decisions
  • We will Increase employee awareness through training

Culture

  • We will involve staff in the implementation of this policy, for greater commitment and improved performance
  • We will update this policy at least annually in consultation with staff and other stakeholders where necessary
  • We will provide staff with relevant environmental training
  • We will work with suppliers, contractors and sub-contractors to improve their environmental performance
  • We will use local labour and materials where available to reduce CO2 and help the community

A paper copy of this policy is signed by the CEO of the company. If you have any queries in relation to this policy, please email environment@ciro-global.com.

COPYRIGHT NOTICE

Copyright © 2014 CiRO, a Registered Trademark.

The copyright in this website and the material on this website (including without limitation the text, computer code, artwork, photographs, images, music, audio material, video material and audio-visual material on this website) is owned by us.

We grant to you a worldwide non-exclusive royalty-free revocable license to:

  • View this website and the material on this website on a computer or mobile device via a web browser
  • Copy and store this website and the material on this website in your web browser cache memory; and
  • Print pages from this website for your own (personal and non-commercial) use

We do not grant you any other rights in relation to this website or the material on this website. All other rights are reserved.

For the avoidance of doubt, you must not adapt, edit, change, transform, publish, republish, distribute, redistribute, broadcast, rebroadcast or show or play in public this website or the material on this website (in any form or media) without our prior written permission.

The automated and/or systematic collection of data from this website is prohibited.

You may request permission to use the copyright materials on this website by writing to enquiries@ciro-global.com.

We take the protection of our copyright very seriously. If we discover that you have used our copyright materials in contravention of the licence above, we may bring legal proceedings against you seeking monetary damages and an injunction to stop you using those materials. You could also be ordered to pay legal costs.

If you become aware of any use of our copyright materials that contravenes or may contravene the licence above, please report this by email to info@ciro-global.com.

If you become aware of any material on our website that you believe infringes your or any other person's copyright, please report this by email to info@ciro-global.com.

WEB POLICY

CiRO LLP ("CiRO" or "The Company") maintains this website to provide information to the internet community.

Such information may be subject to amendment and updating without notice.

The information contained in this website is for general information purposes only. The information is provided by CiRO and whilst we endeavor to keep the information up-todate and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the website or the information, products, services, or related graphics contained on the website for any purpose. Any reliance you place on such information is therefore strictly at your own risk.

In no event will we be liable for any loss or damage including without limitation, indirect or consequential loss or damage, or any loss or damage whatsoever arising from loss of data or profits arising out of or in connection with the use of this website.

Every effort is made to keep the website up and running smoothly. However, CiRO takes no responsibility for and will not be liable for the website being temporarily unavailable due to technical issues beyond our control.

Access to and use of this information is subject to the following terms and conditions:

The sole purpose of this website is to provide information to the reader. It is not intended to form the basis of any advice.

Whilst the information contained within this website is believed to be accurate, no representation or warranty, express or implied, is or will be given by CiRO as to the accuracy or completeness of this information or opinions contained herein.