It is the responsibility of the Finance team to ensure that all taxation issues are promptly reported to and discussed with the CFO as soon as they become aware of them.

Demipower has a low tolerance towards tax risk. The Finance team monitors tax risk across the year and takes all necessary steps to ensure compliance with UK regulations.

Demipower’s attitude to tax planning

Demipower recognises it has a responsibility to pay the appropriate amounts of tax in the UK.

Tax arrangements are simple, well-understood and based on HM Revenue and Customs (HMRC) guidelines. Where there is uncertainty as to the application or interpretation of tax law, appropriate advice evidencing the facts, risks and conclusions is taken from third party advisers to support the decision-making process.

How Demipower works with HMRC

Demipower is committed to being open and transparent in its dealing with HMRC. All dealings are conducted in a collaborative, courteous and timely manner. Demipower commits to:

• adopt open and collaborative professional relationships at all times with HMRC;
• make fair, accurate and timely disclosure in correspondence and returns, and respond to queries and information requests in a timely fashion;
• seek to resolve issues with HMRC in real time and before returns are filed if possible, and where disagreements arise, work with HMRC to resolve issues by agreement (where possible);
• be open and transparent about decision-making;
• reasonably believe that transactions are structured to give a tax result which is not contrary to the economic consequences as expressed in the legislation; and
• interpret the relevant laws in a reasonable way, and ensure transactions are structured consistently with a co-operative relationship

Anti-slavery & Human Trafficking Statement 2024

1: Opening statement from senior management

Demipower Limited, Demipower (1991) Limited, Demipower (2017) Limited, Demipower (Eastern) Limited and New Demipower Limited ("Demipower Group") is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain and imposes the same high standards on its suppliers. This organisation is committed to ensuring there is no slavery or trafficking within its supply chain and operations.

 

2: Structure of the organisation

Demipower Group is a franchisee organisation operating over 1oo restaurants in the fast food sector. It employs over 4,000 people in the United Kingdom with business operations in the United Kingdom.

In order to operate fast food restaurants, we work with a range of suppliers from suppliers of our franchisor, Kentucky Fried Chicken (Great Britain) Limited, to the delivery company. We work closely with our franchisor and our suppliers, managing performance and continuous improvement of quality, service, cost, innovation and risk management.

 

3: Policies

As part of our commitment to combating modern slavery, we have the following policies:

• Anti-Slavery Policy
• Non-Discrimination
• Health and Safety
• Anti-Bribery Policy
• Grievance Procedure

We also endeavour to make sure our suppliers are aware of our policies and adhere to the same high standards.

4: Due diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have adopted due diligence procedures which include requiring suppliers to complete a modern slavery supplier questionnaire, the response of which indicates whether we need to carry out any further audits.

Our procedures are designed to:

• establish and assess areas of potential risk in our business and supply chains

• monitor potential risk areas in our business and supply chains
• reduce the risk of slavery and human trafficking occurring in our business and supply chains

• provide adequate protection for whistleblowers

5: Risk and compliance

Demipower Group regularly evaluates the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain by carefully selecting our main suppliers and working closely with them.

We are conscious that elements of our supply chain are predominately resourced with a seasonal, poorly paid, unskilled workforce and that these industries can be at risk from the abuse of workers and modern slavery. We are confident that our and our franchisor's sourcing practices minimise this risk, particularly in relation to our main suppliers, however that risk can only be minimised if we are continually alert and challenge our supply chain. If we consider there is an unacceptable risk, we wilt write to our suppliers, emphasising our values and ethical standards, and stressing our expectations when working with them. We will use best endeavours to audit our suppliers if reasonably necessary.

We understand that modern slavery including slavery, servitude, trafficking or forced labour, is a constant and increasing global issue that can be found particularly in the food sector, in which we operate.

We understand that indicators of modern slavery include abuse of vulnerability, deception, restriction of movement, isolation, physical and sexual violence, intimidation and threats, retention of identity documents, withholding of wages, debt bondage, abusive working and living conditions and excessive overtime and we place significant importance on identifying such indicators to combat modern slavery.

We use our best endeavours to ensure that our and our franchisor's suppliers adhere to our anti-slavery policy. We enforce a strict code of compliance and do not tolerate slavery and human trafficking within our supply chains. For example, if we find evidence of a failure to comply with our policies, we will seek to terminate our relationship with the relevant supplier.

 

6: Effectiveness

We measure how successful we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains, for example via staff satisfaction surveys and employee relations statistics.

 

7: Training

We invest in educating our staff to recognise the risks of modern slavery and human trafficking in our business and supply chains. Through training, employees are encouraged to identify and report any potential breaches of the organisation's anti-slavery and human trafficking policy. An example of a relevant training course is "KFC UKI RGM: Modern Slavery".

We appreciate that employees are essential to helping keep modern slavery out of our operations and supply chain. Via our franchisor, we provide and publicise a completely confidential helpline called "Speak Up" to encourage our employees to whistle-blow in safety. Our employees are expected to report any suspicions or misconduct in this way and management are expected to act upon such concerns.

 

8: Further actions and sign-off

Following our review of our actions this financial year to prevent slavery or human trafficking from occurring in our business or supply chains, we intend to take the following further steps to tackle slavery and human trafficking:

• Make new employees aware of modern slavery awareness training
• Continue to introduce new policies and procedures to combat slavery and human trafficking

 

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Demipower Group's slavery and human trafficking statement for the financial year commencing 1 November 2023 and ending 31 October 2024.

This statement was approved by the directors of Demipower Group companies on 3 December 2024.

Privacy Policy

Last modified: 02.05.2024

Demipower Limited, Demipower (1991) Limited, Demipower (2017) Limited, Demipower (Eastern) Limited and New Demipower Limited ("Demipower Group") is committed to protecting your privacy.  This Policy describes how we collect, use and disclose your personal information when you visit our sites and in-store kiosks, or otherwise engage with us (“our Service”).

By accessing or using our Service, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal information as described in this Policy.

1. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?

We collect personal information in a variety of ways. For example, you may provide us your personal information when you submit a job application or use some other feature of our Service.

The categories of personal information we collect may include:

Information you provide:

Contact and profile information

We may collect personal information, such as your name, phone number, address, payment card information, business information, gender, age, postcode, and e-mail address, when you communicate or interact with us. We use this information to fulfill your request or transaction and to communicate with you directly.

Payment and transaction information

We may collect information such as items purchased, date and time of your transaction, amount purchased, whether you used a particular coupon or deal, and payment information, such as your credit/debit card or gift card or loyalty program details, when you make an in-store purchase. We use this information to fulfill your order and complete your transaction and detect and prevent fraud.

Comments, chat and opinions

When you contact us directly (e.g., by email, phone or mail), we may transcribe your comments and opinions. We use this information to respond to your question or comment and to evaluate and improve our Service. When you contact us directly to submit a concern, complaint or question, we may transcribe your comments and collect the personal information contained in your communications (e.g., contact information, health or medical information, photos, etc.). We use this information to respond to your questions or concerns, and to evaluate and improve our Service.

Information we collect when you use our sites and our Service:

Location information. We may collect information about your general location if you provide your address or postcode or we may approximate your location based on your IP address.

In-store data we collect:

In-store Wi-Fi. In some locations, we may offer free Wi-Fi services to our guests. Our Wi-Fi network providers may capture certain data from devices you connect to it, such as a unique device identifier. We may also enable Bluetooth or other technologies in our stores which enable us to detect the presence of your device in our stores or provide operational insights.

We may collect information about your in-store transaction such as items purchased, date and time of your transaction, amount purchased, and payment information, such as your credit/debit card or gift card details, when you make an in-store purchase.

In-store video or images. In some locations, we use CCTV cameras in our stores for security, fraud, incident reporting and loss-prevention purposes, or to improve operations and other purposes.

Information collected from applicants for employment:

If you apply for a job directly through us, we collect the information you include in your application, which could include your name, address, phone number, email address as well as sensitive personal information including your work or education background and history and other such information. We may also obtain information about you from your references. We may also receive this information if you submit an application through a third party site or service, or if we receive your information through a recruiter or employment agency. We collect and use the personal information of applicants for employment to evaluate the application and the suitability of employment, and use sensitive personal information collected according to relevant applicable law.

This information will be retained for a period defined by our retention policies, which is tailored to the legal requirements of the location for which you are applying. We may retain an applicant’s personal information for a reasonable time period after the date of application for the purpose of assessing an individual's suitability for other employment opportunities within our organisation, though we have no obligation to do so and the applicant may wish to submit another application to be considered for another job opening of interest.

1. HOW DO WE USE PERSONAL INFORMATION?

To fulfil your requests and provide our Service to you. For example, we may use your information to complete your order or other transactions, deliver orders you place online, or respond to your customer service requests or feedback.

To protect the security and integrity of our business, comply with legal requirements and obligations, or as otherwise permitted by law.  We may use information to protect our company, our affiliates, our customers and our website. We may also use information in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our this Policy or agreements with third parties, to detect and prevent fraud or for crime-prevention purposes, or for any other reason permitted by law.

1. HOW WE SHARE YOUR INFORMATION

We may disclose your information in the instances described below.  For further information on your choices regarding your information, see “Your Choices and Control Over Your Information” below.

Purchasers and third parties in connection with a business transaction:  Personal information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of any or all of our company assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business by an affiliate or third party, or in the event of legal proceedings.

Law enforcement, regulators and other parties for legal reasons:  Personal information may be disclosed to third parties, as required by law, or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of our organisation, our visitors, or others.

In connection with any of the above, we may share information with others in an aggregated or otherwise anonymised form that does not reasonably identify you.

1. YOUR CHOICES AND CONTROL OVER YOUR INFORMATION

Geolocation and device Information:  You control precise location tracking by adjusting your location services settings on your mobile device. We may continue to approximate your location based on your IP address or through other means when you access the Service through a computer or device.

1. HOW WE STORE AND PROTECT YOUR INFORMATION

Data storage and transfer:  Your information collected through our Service may be stored and processed in the United Kingdom or in any country in which we maintain facilities.  Please note that we may transfer information, including personal information, to a country and jurisdiction that have data protection laws that may be more or less restrictive than those required under English law. 

Data retention:  We will retain your personal information as long as reasonably necessary to maintain the Service, to meet legal and accounting obligations, and for the other purposes described in this Policy, or as otherwise required or permitted by law. We may anonymise and/or aggregate personal information and store it in order to analyse aggregate metrics and trends.

Keeping your information safe:  Security of your information is very important to us, and we have put in place safeguards to preserve the integrity and security of information we collect and share with our service providers. However, no security system is impenetrable and we cannot guarantee the security of our systems at all times. In the event that any information under our control is compromised as a result of a breach of data security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take additional steps, in accordance with any applicable laws and regulations.

1. JURISDICTIONAL DISCLOSURES

Please review this section to understand how our practices or policies apply in Europe:

EEA PRIVACY NOTICE

This EEA and UK Privacy Notice supplements the information contained in our Privacy Policy and applies solely to individual residents that are located in the European Economic Area ("you" and to the Sites and Services available in the EEA as well as the UK that link to this Privacy Notice).

Unless otherwise expressly stated, all terms have the same meaning as defined in our Privacy Policy or as otherwise defined in the EU General Data Protection Regulation 2016/679 of the European Parliament and of the Council (“GDPR”). 

For the purposes of EU data protection laws, including the GDPR, we are a data controller (i.e., responsible for, and controlling the processing of, the personal data that has been collected by the controller). 

Legal basis for processing in the EEA and UK: In the EEA and UK, the purposes for which we process your personal data are: 

1)      the provision of personal data by you may be necessary for the performance of any contractual relationship we have with you;

2)      where it is necessary for compliance with our legal obligations laid down by EEA and UK law;

3)      where in our legitimate interests (provided these are not overridden by your interests and fundamental rights and freedoms - this includes our own legitimate interests and those of other entities and branches in our group of companies) such as:

1. to contact you and respond to your requests and enquiries;
2. for fraud prevention and detection; and
3. to comply with applicable laws, regulations or codes of practices.

We may also process your personal data on the basis of your freely given, specific, informed and unambiguous consent. You should be aware that you are entitled under Data Protection Law to withdraw your consent where that has been given, at any time. If you do this and we have no alternative lawful reason to process your personal data, this may affect our ability to provide you with rights to use the Service.

Please see the table at Annex 1 sets out in detail the categories of personal information we collect about you and how we use that information when you use the Service, as well as the legal basis which we rely on to process the personal information and recipients of that personal information.

In addition, the table at Annex 2 sets out in detail the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information and recipients of that personal information.

Data storage and transfer in the EEA and UK: If you are located in the EEA or UK, your information that we collect through our Service will be stored and processed primarily in the EEA or UK. If we transfer information outside of the EEA or UK, we will ensure that:

(a) the personal information is transferred to countries recognised as offering an equivalent level of protection; or

 (b) the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission. Notwithstanding these measures, the country and jurisdiction to which data is transferred may provide for a lower standard of data protection than the one under the EEA or UK law.

Individual rights of residents in the EEA: If you are located in the EEA or UK, you have the following rights in respect of your personal data that we hold:

1. Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation.
2. Right of access. The right to obtain access to your personal data.
3. Right to rectification. The right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete.
4. Right to erasure. The right to obtain the erasure of your personal data without undue delay in certain circumstances, such as where the personal data is no longer necessary in relation to the purposes for which it was collected or processed.
5. Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal data in certain circumstances, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data.
6. Right to portability. The right to portability allows you to move, copy or transfer personal data easily from one organisation to another.

If you wish to exercise one of these rights, please contact us using the contact details at the end of this Notice.

You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Retention: For individuals based in the EEA, we store personal data for as long as necessary to fulfill the purposes for which we collect the data, except if required otherwise by law.

 

HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Service, please contact us: 

dataenquiries@demipower.com

 

ANNEX 1

 

Category of personal information

How we may use it

Legal basis for the processing

Profile information such as your name, phone number and birth date

We may use this information to deal with enquiries and complaints made by or about you relating to the Service

The processing is necessary for our legitimate intersts, such as administering the Service and to communicate with you effectively to respond to your queries or complaints

Payment and transaction information including payment information (such as your credit or debit card details) and time, date and value of transactions

We use this information to:

·         facilitate transactions and provide you with the Service;

·         provide customer support; and

·         to detect and prevent fraud

The processing is necessary for:

·         the performance of a contract with you;

·         our legitimate interests such as detection and prevention of fraud

Comments, chat and opinion

When you contact us directly (e.g. by email, phone or mail) we may record your comments and opinions

The processing is necessary for our legitimate interests, such as responding to your question or comment and to evaluate and improve our Service

 

ANNEX 2

Category of personal information

How we may use it

Legal basis for the processing

Images captured via CCTV

We use CCTV cameras in our stores for security, fraud, incident reporting and loss-prevention purposes, or to improve operations and other purposes

The processing is necessary for security, fraud, incident reporting and loss-prevention and images are stored in accordance with our retention policy

 

1. CHANGES TO OUR PRIVACY POLICY

We may modify or update this Policy from time to time to reflect the changes in our business and practices, so you should review this Policy periodically.  When we change this Policy in a material manner, we will so indicate by updating the “last modified” date in the heading of this Policy.