Strachan Policies

1. Anti-Discrimination and Anti-Harassment Policy

1. We strive always to create and maintain a work environment in which people are treated with dignity, decency and respect in an environment characterized by mutual trust and the absence of intimidation, oppression, exploitation and therefore will not tolerate any discrimination or harassment of any kind against any employee.

2. All employees, regardless of position, are subject to and are expected to fully comply with this policy and to take appropriate measures to ensure that prohibited conduct does not occur.

3. It is a violation of this Policy to discriminate against any person or persons in the provision of employment opportunities, benefits or privileges; to create discriminatory work conditions; or to use discriminatory evaluative standards in employment if the basis of that discriminatory treatment is, in whole or in part, the person’s race, colour, national origin, age, religion, disability status, gender, sexual orientation, gender identity, genetic information or marital status.

4. The Firm also prohibits harassment of any kind, including sexual harassment, and will take appropriate and immediate action in response to reports of violations of this Policy. Harassment includes any verbal or physical conduct designed to threaten, intimidate or coerce an employee, co-worker or any person working for or on behalf of the Firm. Verbal taunting (including racial and ethnic slurs) that, in the employee’s opinion, impairs his or her ability to perform his or her job is included in the definition of harassment.

5. Any violation of this Policy must be reported to the Practice Manger or to the Senior Partner as may be appropriate for investigation. Any employee found to be in violation of this Policy shall be subject the Firm’s disciplinary process.

Please let all join hands to ensure an environment where we can all thrive.

2. Anti-Bribery Policy

Strachan Partners is committed to conducting its business to the highest ethical standards and in compliance with all laws. The Firm rejects all forms of bribery and corruption, and will not resort to nor will it entertain or allow corruption by any member of the Firm or any other person working for or with it for the sake or gaining or retaining business or for any other purpose.

Our Code of Conduct is designed to control effectively, the risks of bribery and corruption and is efficient in the mode of required training for each member of its staff.

SP has and will continue to communicate its Anti-Bribery Policy to its clients and relevant third parties in the course of its business. Staff are encouraged to report any misconduct or potential misconduct, through a direct email to the Senior Partner. This information will be treated in the strictest confidence and the “whistle blower” shall be protected from any reprisals or retaliation.

All Staff of SP are required to conduct themselves with the highest decorum and abide by the highest standards of integrity and accountability, apply exemplary judgment in all their business dealings / relationships. No member of staff shall use his/her position or information derived from that position, for personal gain or for the benefit of others and must seek to uphold and enhance the standing and good name of Strachan Partners in all that they do and in all circumstances.

This Policy and the SP Code of Conduct will be subject to regular review, to confirm that they continue to be fit for purpose and to make necessary adjustments where they fall short.

A breach of this SP Policy will immediately invoke the Firm’s disciplinary process.

3. Anti-Bullying Policy

Strachan Partners will not tolerate any type of bullying by any employee irrespective of position, against another employee or employees of the Firm.

“Bullying” is repeated inappropriate behaviour, whether direct or indirect, verbal, physical or otherwise, conducted by one or more persons against another or others, at the place of work and/or in the course of employment. Such behaviour violates Strachan Partners’ Code of Ethics, which recognises that all employees are entitled to be treated with dignity and respect.

Bullying includes Verbal Bullying: slandering, ridiculing or maligning a person or his or her family; persistent name calling that is in the opinion of the person on the receiving end hurtful, insulting or humiliating; using a person as butt of jokes; abusive and offensive remarks; Physical Bullying: Pushing, shoving, kicking, poking, tripping, assault or threat of physical assault, damage to a person’s work area or property; Gesture bullying: Nonverbal threatening gestures; glances that can convey threatening messages. Exclusion: Socially or​​ physically excluding or disregarding a person in work-related activities.

Other behaviours as contained in the Procedure, may also constitute or contribute to the evidence of bullying in the Firm.

Any violation of this Policy must be reported to the Practice Manager who must investigate and resolve or escalated as appropriate.

4. Data Protection

DATA PROTECTION POLICY
This policy is drafted in accordance with the Nigerian Data Protections Regulations 2019.

1.0 DATA SOURCES
Information or Data required for effective representation of clients may be obtained from the following sources:
1. Data voluntarily provided by clients;
2. Information in public domain; and
3. Information from third parties. Such as;
• Banks and Other Financial Institutions
• Government Institutions and Agencies
• Private Organisations

1.1 DATA PROTECTION-Section 2.1
We recognise that our clients’ information is valuable and we maintain all reasonable measures to protect it whilst it is in our care.
We have exceptional standards of technology and operational security to protect personally identifiable data from breach, loss, misuse, alteration or destruction. Similarly, we adopt a high threshold when it comes to confidentiality obligations and both internal and external parties have agreed to protect confidentiality of all information; to ensure all personal data is handled and processed in line with our stringent confidentiality and data protection policies.

We use computer safeguards; and we enforce, where possible, physical access controls to our buildings and files to keep data safe.

1.2 DURATION OF CLIENTS’ DATA IN OUR CUSTODY- Section 2.13.8
Our clients’ personal information will be retained, usually in a computer or manual files, only for as long as necessary to fulfil the purposes for which the information was collected; or as required by law; or as long as is set out in the client’s terms of engagement.

1.3 RIGHTS OF CLIENTS IN RELATION TO DATA-Section 2.13
Under certain circumstances, in addition to the right to ‘access to data’, our clients have the following rights:

1. THE RIGHT TO BE INFORMED-Section 2.13.6
This is fulfilled by way of this privacy notice and our transparent explanation as to how we use their personal data.

2. THE RIGHT TO RECTIFICATION-Section 2.13.6 (h)
Our clients are entitled to have their personal data rectified if such data is inaccurate or incomplete.

3. THE RIGHT TO ERASURE-Section 2.13.6 (h)
Our clients have the right to request the deletion or removal of their personal data where there is no compelling reason for its continued processing. This right only applies in the following specific circumstances:

• Where the personal data is no longer necessary in regards to the purpose for which it was originally collected;
• Where consent is relied upon as the lawful basis for holding their data and they withdraw such consent;
• Where they object to the processing and there is no overriding legitimate interest for continuing the processing; and
• Where they object to the processing for direct marketing purposes.

4. THE RIGHT TO OBJECT- Section 2.8
Our clients have the right to object to data processing based on legitimate interests. This right only applies in the following circumstances:

• An objection to stop processing personal data for direct marketing purposes is absolute – there are no exemptions or grounds to refuse – we must stop processing in this context;
• We can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms; or
• The processing is for the establishment, exercise or defence of legal claims.

5. THE RIGHT TO RESTRICT PROCESSING-Section 2.13.6(h)
Our clients have the right to request the restriction or suppression of their data. When processing is restricted, we can store the data but not use it. This right only applies in the following circumstances:

• Where they contest the accuracy of the personal data – we should restrict the processing until we have verified the accuracy of that data.
• Where they object to the processing (where it was necessary for the performance of a public interest or purpose of legitimate interests), and we are considering whether our firm’s legitimate grounds override their right.
• If we no longer need the personal data but they require the data to establish, exercise or defend a legal claim.

1.4 COMPLAINTS ABOUT THE USE OF PERSONAL DATA
Complaints and inquiries can be sent in any of the following ways:
Physical Drop Off (8:30 am to 5:30 pm daily):
Lagos – 8, Tokunbo Omisore Street, Off Wole Olateju Crescent, Lekki Phase I, Lagos
Abuja – Suites 312& 313, 2nd Floor, Oakland Centre, 48, Aguiyi Ironsi Street, Maitama, Abuja
Email:
info@strachanpartners.com
Phone Number:
(+234 1) 270 0722, (+234 9) 46029163

Response to complaints and inquiries will be sent out within 24 hours.

1.5 GOVERNING RULES AND REGULATIONS
This policy is drafted in accordance with the Nigerian Data Protections Regulations 2019.

25 years as a leading commercial law practice.

In its 25 years of experience, Strachan Partners has progressively become a legal resource as it has garnered a wealth of in-depth knowledge and industry know-how applicable to numerous facets of the Nigerian economy, in particular the budding sectors of the Nigerian economy to which the financial industry is one of. We challenge the industry norms and deliver a customized quality service to our clients laced with a cost-transparency policy.

E: info@strachanpartners.com
P: (+234) -1-2700722

Give us a call or drop by anytime, we endeavour to answer all enquiries within 24 hours on business days.

Lagos

8 Tokunbo Omisore Street,
Off Wole Olateju Crescent,
Lekki Phase 1.

Abuja

Suite 311, 2nd floor,
Oakland centre, 48,
Aguiyi Ironsi Street,
Maitama, Abuja.





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