Welcome to our Policy Centre. Here you’ll find our Privacy, Grievance, and Whistleblower Protection Policies. Each reflects our commitment to transparency, fairness, and creating a safe environment where concerns can be raised and addressed responsibly.

Privacy Policy

This Statement of Privacy applies to the media-tree.com website (the Website) and governs data collection, processing and usage. By using the Website, you consent to Media Tree Project Ltd data practices described in this statement. If you do not agree to any part of this Statement of Privacy, then you should stop accessing the Website.

Definitions
Capitalised terms in this Policy have the following meanings:

“Customer” means a prospective, current or former customer of Media Tree Project Ltd. The term shall also include any individual agent, employee, representative, customer or client of Media Tree Project Ltd where Media Tree Project Ltd has obtained his or her Personal Data from such Customer as part of its business relationship with the Customer.

“Data Subject” means an identified or identifiable natural living person about whom Personal Data is being processed.

“Employee” means an employee (whether temporary, permanent, part-time or contract) of Media Tree Project Ltd. An employee may be a resident of a country within the European Economic area.

“Europe” or “European” refers to a country in the European Economic Area.

“Personal Data” as defined under the European Union Directive 95/46/EC, Personal Data means data that personally identifies or may be used to personally identify a person, including an individual’s name in combination with country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, e-mail address and password. Personal Data does not include data that is de-identified, anonymous, or publicly available. For Switzerland, the term “person” includes a natural person and a legal entity, regardless of the form of the legal entity.

“Sensitive Data” means Personal Data that discloses a Data Subject’s medical or health condition, race or ethnicity, political, religious affiliations, sexual orientation, or trade union membership.

“Third Party” means any individual or entity that is neither Media Tree Project Ltd nor a Media Tree Project Ltd employee, agent, contractor or representative.

Collection of your Personal Data
Media Tree Project Ltd may collect and process Personal Data, such as your e-mail address, name, home or work address or telephone number. If you purchase Media Tree Project Ltd products and services, we may collect and store billing and credit card information. Media Tree Project Ltd may also collect anonymous demographic information which is not unique to you, such as your postal code, age, gender, preferences, interests and favourites.

Information about your computer hardware and software also may be automatically collected by the Website. This information can include your IP address, browser type, domain names, access times and referring website addresses. This information is used by Media Tree Project Ltd for the operation of the service, to maintain quality of the service and to provide general statistics regarding use of the Website.

Please keep in mind that if you directly disclose Personal Data or Sensitive Data through the Website’s public message boards, this information may be collected and used by others.

Media Tree Project Ltd encourages you to review the privacy statements of websites you choose to link to from the Website, so that you can understand how those websites collect, use and share your information. Media Tree Project Ltd is not responsible for the privacy statements or other content on websites outside of the Media Tree Project Ltd family of websites.

Use of your Personal Data
Media Tree Project Ltd collects and uses your Personal Data to operate the Website and deliver the services. Media Tree Project Ltd will send one welcome email following registration to all registered users. We will also periodically send service updates to registered users.

Media Tree Project Ltd may also use your Personal Data to inform you of other products or services available from Media Tree Project Ltd and its affiliates, where you have consented to be contacted for such purposes. Media Tree Project Ltd may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered, although you do not have to respond to such surveys.

Storage of Personal Data
As part of the services offered to you through the Website, the information you provide to us may be transferred to and stored in countries outside of the European Economic Area (EEA). It may also be processed by Employees operating outside the EEA who work for us or one of our suppliers. By way of example, a transfer of your information may happen if any of our servers are located in a country outside of the EEA or one of our service providers is located in a country outside of the EEA.

If we transfer or store your information outside the EEA in this way, we will take all steps reasonably necessary to ensure that your privacy rights continue to be protected and treated securely as outlined in this Statement. If you use our service while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with these services. By submitting your Personal Data, you agree to this transfer, storing or processing by us.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Media Tree Project Ltd keeps track of the websites and pages our customers visit within the Website, in order to determine what website services are the most popular. This data is used to deliver customised content and advertising within the Website to customers whose behaviour indicates that they are interested in a particular subject area.

Media Tree Project Ltd will disclose or share your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) comply with any legal requirements or comply with legal process served on the Website; (b) protect and defend the rights or property of Media Tree Project Ltd; and, (c) act under exigent circumstances to protect the personal safety of users of the Website, or the general public.

Media Tree Project Ltd may disclose your Personal Data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

Disclosures/onward transfers of Personal Data
Media Tree Project Ltd does not sell, rent or lease its customer lists to Third Parties. Media Tree Project Ltd may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your Personal Data is not transferred to the Third Party without your express consent. In addition, Media Tree Project Ltd may share data with trusted partners to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. Media Tree Project Ltd may share your information with Third Parties who perform tasks required to complete a purchase transaction.

All such Third Parties are prohibited from using your Personal Data except to provide these services to the Website, and they are required to maintain the confidentiality of your information by agreeing to provide adequate protections for the Personal Data that are no less protective than those set out in this Statement.

We may disclose your Personal Data to Third Parties: (a) in the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets; and (b) if the Website or substantially all of its assets are acquired by a Third Party, in which case, Personal Data held by it about its Customers will be one of the transferred assets.

Sensitive Data
Sensitive Data is any sensitive data relating to you, including information about your political opinion, religious beliefs or any other beliefs of a similar nature. Media Tree Project Ltd will not process Sensitive Data about you without your express consent.

Use of cookies
The Website uses “cookies” to help you personalise your online experience. A cookie is a text file that is placed on your hard drive by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the server that you have returned to a specific page. For example, if you personalise the Website pages, or register with the Website site or services, a cookie helps the Website to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same the Website, the information you previously provided can be retrieved, so you can easily use the Website features that you customised.

We may use any of the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to the Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies. These cookies record your visit to the Website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to access all or parts of our site or to fully experience the interactive features of the Media Tree Project Ltd services or websites you visit.

Data security & Integrity
Any and all personal information that we may collect will be collected, used and held in accordance with the provisions of General Data Protection Regulation (EU 2016/679) and your rights and Our obligations under that Act. The Website secures your Personal Data from unauthorised access, use or disclosure. The Website secures the Personal Data you provide on computer servers in a controlled, secure environment, protected from unauthorised access, use or disclosure. When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Your rights
You have the right to ask us not to process your Personal Data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at info@media-tree.com

Right to access, change or delete Personal Data
Right to access: the Act gives Data Subjects the right to access information held about them, to ensure that such Personal Data is accurate and relevant for the purposes for which the Website collected the data. You may review your Personal Data stored in the Website databases and correct, erase or block any data that is incorrect, as permitted by applicable law. Your right of access can be exercised in accordance with the Act.

You may edit your Personal Data by logging into your account or by contacting us by phone or email. In making modifications to your Personal Data, you must provide only truthful, complete and accurate information.

Satisfying Requests for Access, Modifications, and Corrections: we will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.

Employees: Media Tree Project Ltd Employees may access and use Personal Data only if they are authorised to do so and only for the purpose for which they are authorised.

Changes to this Statement
Media Tree Project Ltd will occasionally update this Statement of Privacy to reflect company and customer feedback. Media Tree Project Ltd encourages you to periodically review this Statement to be informed of how Media Tree Project Ltd is protecting your information.

Contact information
Media Tree Project Ltd welcomes your comments regarding this Statement of Privacy. If you believe that the Website has not adhered to this Statement of Privacy, please contact us at info@media-tree.com

Grievance & Complaints Mechanism

We are committed to operating ethically, transparently, and responsibly. If you have a concern about our behaviour, decisions, impacts, or how we conduct our work, we encourage you to tell us. This mechanism is open to anyone affected by our activities; including employees, customers, partners, suppliers, and community members.

1. How to Submit a Grievance

You can formally submit a grievance through either of the following channels:

• Email: Send your concern to clientservice@media-tree.com
• Telephone: Call our office and request to submit a grievance at +44 (0) 20 7437 3322
• You may choose to submit a grievance anonymously through our form which can be found by clicking here.

2. Additional Worker Reporting Options

Employees and workers have several ways to raise concerns, including:

Open Door Policy

Workers can speak directly with their manager, team lead, or any member of leadership at any time about concerns.

Internal Discussion Routes

• Raise issues verbally with HR or management
• Request a private meeting to discuss concerns
• Escalate matters through a senior manager if needed

3. What You Can Report

We accept grievances regarding:

• Unfair treatment, harassment, discrimination, or misconduct
• Unsafe or unhealthy working conditions
• Breaches of our Code of Conduct or unethical behaviour
• Environmental or community impact concerns
• Customer service or product-related issues
• Human rights concerns
• Supplier or partner behaviour inconsistent with our standards
• Any situation where harm has occurred or could occur

If a concern is not accepted as a formal grievance, we will explain why.

4. How We Handle Grievances

We follow a clear, transparent process:

Step 1: Acknowledgement

We acknowledge receipt within 5 business days, unless the submission is anonymous.

Step 2: Assessment

We review the issue to determine whether it qualifies as a grievance and clarify any needed information.

Step 3: Investigation

We gather information, speak with relevant people, and review documents.
We aim to complete investigations within 20 business days, depending on complexity.

Step 4: Resolution

If a grievance is upheld, we may take actions such as:

• Corrective or remedial measures
• Mediation or facilitated discussions
• Process or policy changes
• Additional training
• Compensation or remediation where appropriate

Step 5: Outcome

We communicate the outcome and any actions taken to resolve the concern.
If a grievance is not accepted, we explain the rationale.

5. Protection from Retaliation

We strictly prohibit retaliation against anyone who raises a concern in good faith.

Retaliation includes:

• Dismissal or threats
• Demotion, reduction of hours, or negative job changes
• Harassment, bullying, or intimidation
• Any disadvantage or negative treatment resulting from speaking up

All reports are handled confidentially, and anonymous submissions are accepted.
If you believe you have been retaliated against, please contact us immediately.

6. Review & Improvement

We regularly review this mechanism to ensure it is effective, easy to use, and aligned with best practices and the UN Guiding Principles on Business and Human Rights.

Contact

If you have questions about this process or wish to submit a grievance, please contact:

Anonymous link: Mediatree – Grievance & Complaints Form – Fill in form
Email: clientservice@media-tree.com
Telephone: +44 (0) 20 7437 3322

Whistleblower Protection Policy

Mediatree is committed to maintaining a culture of integrity, transparency, and accountability. We encourage all stakeholders (including employees, contractors, suppliers, customers, and community members) to report concerns about unethical, illegal, harmful, or unsafe behaviour without fear of retaliation.

This Whistleblower Protection Policy outlines the protections, processes, and safeguards in place to ensure anyone who raises a grievance or complaint can do so safely and confidentially.

1. Purpose

The purpose of this policy is to:

• Protect individuals who report concerns (“whistleblowers”) from retaliation
• Ensure grievances and complaints can be raised freely
• Safeguard confidentiality throughout the process
• Support fair investigation of concerns
• Promote ethical conduct and responsible business practices

This policy applies to all staff, leadership, suppliers, partners, and other stakeholders.

2. Our Commitment to Protect Whistleblowers

We strictly prohibit any form of retaliation against anyone who raises a concern in good faith. This includes grievances submitted anonymously or through our formal grievance channels (email or telephone).

Retaliation is defined as:

• Dismissal, demotion, or loss of hours
• Negative changes to job duties or working conditions
• Harassment, bullying, or intimidation
• Threats or coercion
• Blacklisting or reputational harm
• Any disadvantage or adverse treatment linked to speaking up

Any individual found to have retaliated against a whistleblower will face disciplinary action, up to and including termination of employment or termination of contract.

3. Whistleblower Protection Measures

To ensure whistleblowers are protected, we have implemented the following safeguards:

3.1 Confidentiality

• All reports are treated as strictly confidential.
• Identifying information is only shared with people who must be involved to investigate the matter.
• We seek consent before involving additional parties wherever possible.
• Investigation outcomes are shared only on a need-to-know basis.

3.2 Anonymous Reporting

Whistleblowers may report concerns anonymously through:

• Our grievance email address
• Telephone reporting without giving a name
• Our anonymous MS Forms grievance form

3.3 Risk Assessment

• We assess potential risks to every whistleblower at the outset of the investigation.
• Where needed, we involve independent or third-party assessors to evaluate risks, especially for vulnerable groups.
• Protective measures (adjusted duties, temporary separation, safe reporting routes) may be implemented.

3.4 Communication

We inform whistleblowers:

• Who will receive or review their report
• What steps will be taken
• The intended timing of the investigation
• What information may need to be shared, and with whom

3.5 Non-Retaliation Enforcement

• Any retaliation will be investigated as a serious policy breach.
• Disciplinary action will apply for confirmed retaliation or confidentiality breaches.
• Contractors or suppliers who retaliate may face immediate contract review or termination.

4. What Can Be Reported

Whistleblowers are encouraged to raise concerns about:

• Unethical, illegal, or fraudulent behaviour
• Corruption, bribery, or conflicts of interest
• Discrimination, harassment, or unsafe working conditions
• Environmental or community harm
• Human rights violations or labour rights breaches
• Violations of company policies or standards
• Supplier or partner misconduct
• Any activity that could harm people, the community, or the environment

Concerns may be raised even if the whistleblower is unsure whether a breach has occurred.

5. How to Report a Concern

Whistleblowers can report concerns through:

• Email: clientservice@media-tree.com
• Telephone: +44 (0) 20 7437 3322
• Anonymous Online Form: Mediatree – Whistleblower Report Form – Fill in form

These channels support both identified and anonymous reporting.

6. Investigation Process

Once a concern is raised, we follow a structured process:

6.1 Acknowledgement

If contact details are provided, we acknowledge receipt within 5 business days.

6.2 Initial Assessment

We assess:

• The nature of the concern
• Any immediate risks
• What information is needed
• Which individuals need to be involved

6.3 Investigation

• Conducted by a trained internal representative or independent third party.
• Information is shared on a need-to-know basis only.
• We keep the whistleblower informed of key steps when possible.

6.4 Outcomes

Possible actions include:

• Corrective or remedial measures
• Training or policy updates
• Disciplinary action for misconduct
• Referral to authorities if appropriate

We maintain confidentiality regarding the outcome and share only what is necessary to confirm the issue has been addressed.

7. Training and Responsibilities

• All managers involved in handling grievances receive enhanced training on confidentiality, risk assessment, and anti-retaliation principles.
• Leadership is responsible for ensuring this policy is implemented and upheld.
• All employees and partners must comply with non-retaliation and confidentiality requirements.

8. Policy Violations

Violations of this policy (including retaliation or breach of confidentiality) will result in disciplinary action. In case retaliation of whistleblowers is identified, or if any violation of this policy is identified,  disciplinary action may include:

• Formal warning
• Mandatory training
• Loss of responsibilities
• Termination of employment
• Termination of supplier/partner agreements

Serious breaches may be reported to external authorities.

9. Review of this Policy

We review this policy annually or following any significant incident to ensure continued alignment with best practices and standards, including the B Corp guidance, UNESCO, and ICC recommendations.

Contact Us

For questions about this policy or to raise a concern, please contact:
Email: clientservice@media-tree.com
Phone: +44 (0) 20 7437 3322
Anonymous form: Mediatree – Whistleblower Report Form – Fill in form