Compliance Policy

1) Purpose & Scope

This policy sets out how Chaskah Ltd meets its legal, regulatory, and ethical obligations across product safety (including pressurised gas), data protection, anti-bribery, modern slavery, transport/storage of dangerous goods, and general health & safety. It applies to all UK operations and to third parties acting on our behalf.

2) Roles & Responsibilities

• Board/Directors: Own overall compliance and risk oversight.
• Managers: Implement controls day-to-day and ensure teams comply.
• All staff & contractors: Read, understand, and follow this policy; report concerns immediately.

3) Legal & Regulatory Framework

• UK GDPR & Data Protection Act 2018 (personal data, rights, security). ICO
• Health and Safety at Work etc. Act 1974 (employer and employee duties). HSE
• Pressure Equipment (Safety) Regulations 2016 (placing pressure equipment on the GB market). GOV.UK
• Carriage of Dangerous Goods & Use of Transportable Pressure Equipment Regulations 2009 (CDG 2009) + ADR (transport/storage of pressurised goods). HSE+1
• Misuse of Drugs Act 1971 (nitrous oxide: Class C, with legitimate-use exemptions)—we only supply for lawful, legitimate uses. GOV.UK
• Bribery Act 2010 (adequate procedures to prevent bribery). GOV.UK
• Modern Slavery Act 2015 (zero tolerance of forced labour; proportionate due diligence).

4) Controlled & Age-Restricted Products (Nitrous Oxide & Pressurised Gas)

4.1 Legitimate-use only
‍
We sell pressurised gas (e.g., cream/nitro chargers) only for lawful catering, hospitality, or other legitimate uses. Sale or supply for recreational inhalation or other unlawful purposes is prohibited. Staff must refuse suspicious orders. GOV.UK

‍4.2 Due diligence & verification4.3 Storage, handling & transport

• Store cylinders upright, cool, dry, ventilated; keep away from heat/ignition; handle per manufacturer guidance.
• Follow CDG 2009/ADR requirements for classification, packaging, labelling, and transport documentation; use trained carriers.

• Business checks (e.g., company details, VAT/GEO checks) for trade customers.
• KYC/age verification for relevant sales; minimum 18+ policy.
• “Know your customer” red-flags list (e.g., unusual quantities, residential bulk orders, requests for plain-label packaging, pressure for cash).
• Record outcomes of checks against the order ID for audit.

5) Product Safety & Quality

• Source from approved suppliers with conformity evidence (e.g., declarations to PE(S)R) 2016 where applicable). GOV.UK
• Maintain lot/batch traceability (supplier → customer).
• Issue safety/data sheets and user guidance where required.
• Non-conforming product process: quarantine, investigate root cause, notify affected customers if needed, and document corrective actions.

6) Health & Safety (H&S)

• Conduct and record suitable risk assessments, method statements, and workplace inspections.
• Provide training/briefings on manual handling, cylinder handling, PPE, and emergency response.
• Report and investigate near-misses, incidents, and RIDDOR-reportable events; implement corrective actions.
• Duties follow the HSWA 1974 general principles.

7) Data Protection & Privacy

• Process personal data lawfully, fairly, and transparently; follow data-minimisation and security principles.
• Honour rights requests (access, rectification, erasure, objection, portability) within statutory timelines.
• Use processors under written contracts with appropriate security; complete DPIAs for higher-risk processing.
• For personal-data breaches likely to risk individuals’ rights/freedoms, assess promptly and notify the ICO within 72 hours where required; inform affected individuals when legally required. See our Privacy Policy for details.

8) Anti-Bribery & Corruption (ABC)

• Zero tolerance of bribery, facilitation payments, kickbacks, or improper gifts/hospitality.
• Follow the six principles (proportionate procedures, top-level commitment, risk assessment, due diligence, communication/training, monitoring & review).
• Record gifts/hospitality in the register; pre-approval for anything above [£X].
• Third parties (agents/distributors) must pass due-diligence checks and contractually agree to ABC clauses.

9) Modern Slavery & Ethical Sourcing

• We prohibit forced, bonded, or child labour and human trafficking across our operations and supply chain.
• Risk-based supplier due diligence (country, sector, product risk), contractual undertakings, and remediation expectations.
• A whistleblowing channel is available to raise concerns safely and confidentially (see Section 11).

10) Environment (Packaging & Waste)

• Minimise waste; use recyclable packaging where feasible.
• Work with carriers and customers to manage returns/recycling safely for used cylinders where applicable.
• Keep records to meet any applicable producer/packaging obligations.

11) Training & Awareness

• Induction: compliance essentials for all starters.
• Annual refreshers: H&S, product safety/transport, data protection, and ABC.
• Role-specific: warehouse/courier handling of pressurised goods; sales due-diligence.

12) Monitoring, Audits & Record Keeping

• Periodic internal audits of orders, due-diligence files, transport logs, incident reports, and training completion.
• Supplier audits based on risk tier.
• Keep records for statutory periods (e.g., financial 6 years; due-diligence aligned to product lifecycle and legal needs).

13) Incident & Breach Response

• Safety/product incidents: isolate stock, investigate, and notify customers/regulators where required.
• Data incidents: follow Section 7 breach protocol and ICO notification rules where applicable. ICO
• Compliance breaches: record, correct, and—where material—escalate to Directors.

14) Supplier & Partner Expectations

Suppliers must:

• Comply with all laws cited in Section 3 (or equivalent in their jurisdiction).
• Maintain safe workplaces, fair pay/hours, and no forced/child labour.
• Provide product conformity evidence and cooperate with audits.
• Report serious incidents or regulatory actions affecting supplied products within 48 hours.