Policies and Legal Notices

Data Privacy Cookies Modern Slavery
Data Privacy

Ultra Electronics is committed to safeguarding the privacy of the personal data of our employees, customers, suppliers and partners. This Data Privacy Notice sets out how Ultra Electronics (Ultra) uses and protects any personal data that you provide. Personal data means any information relating to an identified or identifiable natural person; an identifiable person is one who can be directly or indirectly identified by reference to an identifier such as name, an identification number, location data, online identifier or to one or more factors specific to the physical physiological, genetic, mental, economic, cultural, or social identity of that natural person.

In providing personal data (via submission of a business card, job application, e-mail address, e-mail sign off, or by registering for information via our web sites for example) you can be assured we are committed to protecting your privacy and that your personal data will only be used in accordance with this Data Privacy Notice and for the legitimate purpose for which it has been collected.

In taking affirmative action by providing your personal data as described above you are agreeing to the collection, storage or processing of your personal data in the manner described in this privacy notice.

In taking affirmative action by providing your personal data as described above you are agreeing to the collection, storage or processing of your personal data in the manner described in this privacy notice.

Collecting personal data

We may collect personal data from you as a result of many types of interactions including visiting our web site, applying for a position or day to day business activity. The following list shows the type of information that we may record for business purposes:

  • Name, Company and job title
  • Contact information including e-mail address
  • Demographic information such as postcode, preferences and interests
  • Information relating to your market sector or business domain
  • Other information relevant to customer surveys, business transactions or opportunities or employment (please refer to the job Applicant information at the bottom of this Data Privacy Notice)

Our interest in collecting and retaining this information is to fulfil our transaction with you and in particular for, but not limited to, the following reasons:

  • To contact you for business purposes by e-mail, telephone, fax or post
  • To contact you about current and potential business and employment opportunities
  • To send newsletters
  • To invite you to business events
  • To improve our products and services and for other market research
  • For internal record keeping
  • To send promotional materials or other information we think you may find interesting using the contact details you have provided
Sharing your personal data

We respect your privacy and will not share any identifiable information collected from you via whatever means except when required by law, including (without limitation) in order to comply with applicable local laws or judicial proceedings, court orders or any other legal processes. Any personal data you share with us will be treated with care and for the purposes you have agreed to.

Storing your personal data

We are committed to ensuring that your information is secure. In order to prevent unapproved access or disclosure we have put in place suitable technical and organisational measures to safeguard and secure the information we collect.

Retaining your personal data

We will hold your personal data for an appropriate period in order to effectively manage our relationship with you. We will carry out periodic reviews of the personal information to ensure it is up to date and accurate.

Your rights

Your rights in connection with providing us with personal data are:

Access – you can, where permitted by the General Data Protection Regulation, request access to a copy of your personal data and further information regarding how we deal with your personal data

Accuracy – you can request that we correct, delete or restrict the processing of any inaccurate personal data we hold

Erasure – you can request that we erase personal information we are holding where it is no longer being used for the purpose it was originally submitted for

The General Data Protection Regulation (EU) 2016/679 (GDPR) is a regulation in EU law on data protection and privacy for all individuals within the European Union (EU) and the European Economic Area (EEA). It also addresses the export of personal data outside the EU and EEA areas. The GDPR aims primarily to give control to individuals over their personal data and to simplify the regulatory environment for international business by unifying the regulation within the EU.

Use of Cookies

It is our policy to use cookies for anonymous analysis (tracking the timing and dates of visits, pages viewed for example). For further information our Cookie Policy please review our Cookie Policy.

Links to other websites

As a convenience to visitors, our web site may contain links to other third party web sites. Ultra is not responsible for the privacy practices or the content of such web sites and it is recommended that users read the individual privacy policy statements of each web site visited.

Further information

If you have any questions or concerns about how we handle your personal data, or to exercise your rights, our Group Data Protection Officer can be contacted via:

E-mail: dpo@ultra-electronics.com. Post: Group Data Protection Officer Ultra Electronics 417 Bridport Road Greenford Middlesex UB6 8UA United Kingdom

Individuals have the right at any time to contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (or any other appropriate supervisory authority). Details of how to contact the ICO can be found via their website: https://ico.org.uk.

Other locations are listed in the ‘Contact’ page.

Changes to this Data Privacy Notice

We reserve the right to review the information contained in this Data Privacy Notice, please refer back to this page frequently to see any changes or updates.

Recruitment

As part of any recruitment process Ultra collects and processes personal data relating to job applicants. This Data Privacy Notice applies to all prospective applicants and candidates during the recruitment and selection process for a role within Ultra. The application could be for a permanent, temporary or fixed term contract of employment as well as applications from candidates applying for an Apprenticeship or Graduate placement or to provide services via a Limited Company supplier agreement or through an Employment Agency or Umbrella Company.

Cookies

Page last updated: November 2019

1. About cookies

1.1 What are cookies?

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

1.2 Persistent and session cookies

Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web 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.

2. Cookies that we use

2.1 Strictly necessary cookies

Strictly necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

CookiePurpose
ASP.NET_SessionIdPreserves the visitor's session state across page requests.

2.2 Analytical/Performance Cookies

Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.

CookiePurpose
_gaRegisters a unique ID that is used to generate statistical data on how the visitor uses the website.
_gat
Used by Google Analytics to throttle request rate.
_gid
Registers a unique ID that is used to generate statistical data on how the visitor uses the website.
3. Managing cookies

3.1 Most browsers allow you to refuse to accept cookies and to delete cookies.

The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

  1. Chrome – https://support.google.com/chrome/answer/95647?hl=en
  2. Internet Explorer  https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
  3. Edge – https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
  4. Firefox – https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
  5. Safari – https://support.apple.com/kb/PH21411
  6. Opera – http://www.opera.com/help/tutorials/security/cookies/

You can manage the cookies used on our website at anytime by visiting our cookie portal.

3.2 Negative impact of blocking cookies

If you block cookies, you will not be able to use all the features on our website.

4. Amendments

4.1 We may update this policy from time to time by publishing a new version on our website.

4.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

4.3 We may notify you of changes to this policy by email or through a message on our website.

5. Our details

5.1 This website is owned and operated by Ultra Electronics Holdings PLC.

5.2 Our principal place of business is at 35 Portman Square, Marylebone, London W1H 6LR.

5.3 You can contact us:

  1. by post, using the postal address given above;
  2. using our website contact form;
  3. by telephone, on +44 (0) 208 813 4321; or
  4. by email, using information@ultra-electronics.com
6. Data protection officer

6.1 Our Group Data Protection Officer can be contacted via e-mail dpo@ultra-electronics.com. Individuals have the right at any time to contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. Details of how to contact the ICO can be found via their website: https://ico.org.uk.

Modern Slavery

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking. These have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. Ultra Electronics and its subsidiaries (“Ultra”) has a zero-tolerance approach to modern slavery.

Ultra is committed to acting ethically and with integrity in all its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery does not take place anywhere in its business or in any of its supply chains.

Our structure

Ultra Electronics Holdings plc is the group parent company. Its head office is in the UK and it also has other global offices and facilities, predominantly in the USA, Australia and Canada.

Our businesses

Ultra is organised into 16 business units operating through its three divisions: Aerospace & Infrastructure; Communications & Security and Maritime & Land.

Aerospace & Infrastructure

  • Energy (comprising Nuclear Control Systems* and Nuclear Sensors & Process Instrumentation)
  • Precision Control Systems*

Communications & Security

  • 3eTI
  • Advanced Tactical Systems
  • Communications & Integrated Systems*
  • Forensic Technology
  • Herley
  • TCS

Maritime & Land

  • Avalon Systems
  • Command and Sonar Systems*
  • EMS Development Corporation
  • Flightline Systems
  • Maritime Systems
  • Ocean Systems
  • PMES*
  • USSI

* trading names for Ultra Electronics Limited

We provide a wide range of specialist capabilities in the Defence & Aerospace, Security & Cyber and Transport and Energy Markets. Ultra’s core markets are in North America, the UK and Australia, however we will continue to develop strategic positions where there is strong growth potential.

Our supply chains

Each of our business units operate autonomously and have responsibility for management of their own supply chain. Policy and guidance is provided centrally from Head office and via the Ultra Procurement Council.

Ultra is committed to ensuring there is transparency in its business and in its approach to tackling modern slavery throughout its supply chains. To this end, modern Slavery is a regularly discussed at the Procurement Council meetings.

The Procurement Council has determined that, in general, Ultra has a low dependency on goods and services from suppliers that present a high modern slavery risk. The goods and services procured by our businesses tend to be Commercial Off the Shelf (COTS) products, high-end technology or consultancy / professional services from within North America, the UK, Australia or other low risk territories.

The following steps have been introduced by the Procurement Council to prevent modern slavery occurring within Ultra’s supply chains in the future:

  1. Determining and maintaining acceptable procedures for supplier pre-qualification;
  2. Ongoing assessment of modern slavery risks based on high country risks and high sector risks;
  3. Developing common local modern slavery policies;
  4. Providing a forum for discussing and recording modern slavery occurrences (if any) and preventing future occurrences;
  5. Developing and introducing training for relevant employees in Modern Slavery

Ultra expects the same high standards from all of its contractors, suppliers and other business partners and this is communicated:

  • In its commercial contracts with external organisations,
  • When adding/pre-qualifying suppliers to its vendor base,
  • When conducting audits or visits at supplier sites.
Our policies on slavery and human trafficking

Business Managing Directors and Presidents are responsible for the implementation of local slavery and human trafficking policies within their respective businesses. Divisional MDs/Presidents are responsible for monitoring policy compliance by the businesses within their division.

Managing Directors and Presidents shall ensure that:

  • A written policy is maintained by their business which strictly prohibits: the use of modern slavery in their business or their supply chains; and their business does not support or engage suppliers where they are aware of modern slavery within the suppliers’ business or supply chains.
  • Their business has in place systems to: identify and assess potential risks of modern slavery in their business and their supply chains; mitigate the risk of modern slavery occurring in their business and supply chains; and monitor potential risk areas in their business and supply chains.
  • Terms and conditions of purchase forbidding the use of modern slavery practices are adopted by their business with the right to terminate a relationship with a supplier if issues of noncompliance are discovered and/or noncompliance is not addressed in a timely manner.

We have an independently managed confidential reporting line for employees and third parties to report any concerns in relation to modern slavery.

Training

Managing Directors and Presidents have responsibility for providing adequate and regular training to employees in their business to ensure a high level of understanding of the risks of modern slavery occurring in their business and supply chains.

Measuring effectiveness

The effectiveness of Ultra’s Modern Slavery policy is measured in the following ways:

  1. Business compliance with its local modern slavery policy;
  2. Rolling refresh of business risk assessments to ensure any changes in the profile of supply chain risks are considered, assessed and appropriately managed.
  3. Review of:
    1. the terms and conditions businesses have with their suppliers;
    2. the due diligence processes adopted by businesses; and
    3. the modern slavery training that has taken place in each business.
  4. Recording and monitoring modern slavery incidents (if any) within Ultra’s supply chains and, where necessary, developing corrective measures.

The Procurement Council provides oversight and challenge to this review process.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Ultra’s slavery and human trafficking statement for the financial year ending 31 December 2018.

The board of directors of Ultra Electronics Holdings plc. approved this statement at its board meeting dated 1 August 2019.

Simon Pryce
Chief Executive