Privacy Policy

MUTUAL TRADING CO., INC. PRIVACY NOTICE
PRIVACY POLICY
Last Updated: March 18, 2021

Scope of Disclosures
This Privacy Policy explains how Mutual Trading Co., Inc., our subsidiaries and our affiliated entities (collectively, “we,” “our,” or “us”) collects, uses, discloses, and otherwise processes personal information about individual residents of the State of California (“consumers” or “you”), either online or offline, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”).

Unless otherwise expressly stated, all terms in this Privacy Policy have the same meaning as defined in the CCPA.

What is Personal Information?
When we use the term “personal information”, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or California household.

For the purposes of this Privacy Policy, personal information does not include the following:

Publicly available information from government records.
Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.
Information excluded from the CCPA’s scope, such as:
Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act or clinical trial data.
Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act or California Financial Information Privacy Act, and the Driver’s Privacy Protection Act of 1994.
Information relating to our employees, contractors, staff and other personnel, collected and processed within the employment context.
Our Collection and Use of Personal Information
We collect, use and disclose consumers’ personal information for our everyday business purposes, including marketing of our products and services; processing and fulfilling orders; maintenance of the safety, security, and integrity of our websites and other assets; compliance with legal and regulatory obligations, and more.

We collect some of this information from you directly, when you contact us by phone or email or vice-versa; when you submit a webform on our website; when you register to become our customer or subscribe to our incentive or promotional programs; or when you purchase our products and provide us with information necessary to fulfil the transaction (such as your name, address, telephone number and payment information). You may always choose not to provide us with this information, but if you choose not to, you may not be able to access certain of the features or products we offer.

In addition to any information which you provide to us directly, we may automatically collect certain personal information from you whenever you visit and interact with our website, in order to customize your experience with us. For instance, we use a variety of technologies (such as cookies) that may automatically or passively collect and store information about your online interactions, including your browser operating system and device type, general location, browsing history, and more. We treat such usage information as personal information to the extent required by the CCPA.

In certain circumstances, we may also receive certain personal information about you from third parties including service providers working on our behalf. For example, we may receive information about you when you apply for a job with us through one of our service providers, or when you participate in one of our training or certification programs. Such third-party information enhances our ability to best serve you.

What Categories of Personal Information Do We Collect?
Set forth below are the categories of personal information that we have collected from our consumers in the preceding twelve (12) months, as well as the sources from which we have collected such information, and the purposes governing its collection. Please note, however, that the types of personal information we collect, and the manner in which we collect them, depend largely on the nature of your relationship with us. Therefore, not all of the categories below may apply to you. If you wish to obtain further details about the personal information which we collect about you personally, you may exercise your right to know, which is described in the section of this Privacy Policy entitled “Your California Privacy Rights.”

Categories of Personal Information Collected Categories of Sources Commercial and/or Business Purpose for Collection and Use of Personal Information
Identifiers, such as full name, delivery or billing address, email address, telephone or fax number, social security number, driver’s license, unique personal identifiers (cookies, IP address, customer number, etc.). • Direct from consumer when the consumer signs up for an account with us, places or returns an order or otherwise transacts with us, subscribes to our newsletter, contacts us by phone, email or webform, submits a product or service evaluation, etc.
• Automated collection when the consumer interacts with our website through the use of cookies.
• Third-party service providers such as shipping service providers that fulfil consumer orders, and recruiting platforms that receive and process job applications. Commercial Purposes
• Promoting our products and services through our newsletter and promotional offers (such as first-time order discounts).
• Selling our products and services.
Business Purposes
• Detecting and protecting against security incidents.
• Debugging to identify and repair errors on our website.
• Conducting website analytics in order to improve website performance and provide interest- and location-based advertising and marketing.
• Improving our products and enhancing our services.
• Performing regular business functions, such as maintaining consumer accounts, providing customer service support, processing or fulfilling orders and transactions, verifying consumer information, and contracting with service providers to assist in these functions.
Personal information categories listed in the California Customer Records (Cal. Civ. Code § 1798.80(e)), such as name, bank or credit card number, and certain of the “identifiers” listed above (telephone number, address, email address, social security number, driver’s license, etc.).

• Direct from consumer when the consumer signs up for an account with us, places an order or return or otherwise transacts with us, subscribes to our newsletter, contacts us by phone, email or webform, etc.
• Third-party service providers such as anti-fraud service providers which help us prevent against fraud and other illegal conduct, recruiting platforms that receive and process job applications, and payment processors and shipping service providers that complete transactions and fulfil customer orders.
Commercial Purposes
• Promoting our products and services through our newsletter and promotional offers (such as first-time order discounts).
• Selling our products and services or enabling order refunds.
Business Purposes
• Detecting and protecting against fraudulent or illegal activities.
• Performing regular business functions, such as maintaining consumer accounts, providing customer service support, processing or fulfilling orders and transactions, verifying consumer payment information, and contracting with service providers to assist in these functions.
Commercial Information, such as purchasing or consuming history of our products or services, including records of products or services purchased, obtained or considered (including feedbacks on our events).

• Direct from consumer when the consumer places an order, exchange or return or otherwise transacts with us for our products or services.
• Third-party service providers such as payment processors when the consumer purchases, returns or exchanges certain products or services.

Commercial Purposes
• Selling our products and services to companies and consumers.
Business Purposes
• Performing regular business functions, such as providing customer service support, processing or fulfilling orders and transactions, verifying consumer information, accounting, and contracting with service providers to assist in these functions.
• Conducting analytics of purchase activities such as records of products or services purchased, obtained or considered (including feedbacks on our events) for general marketing and inventory purposes.

Internet/Network Information, such as browsing and search history on our Website (including the pages viewed, time and duration of views), IP address, device and browser type, operating system, internet service provider, etc.

• Automated collection when the consumer interacts with our website through the use of third-party cookies and logs.

Business Purposes
• Detecting and protecting against security incidents and fraudulent or illegal activities.
• Debugging to identify and repair errors on our website.
• Conducting website analytics in order to improve website performance.
• Tracking consumers’ online interactions and browsing history for general marketing and inventory purposes.
Geolocation Data, such as your IP address, general device physical location, etc.

• Direct from consumer when the consumer contacts us by phone, email or webform.
• Automated collection when the consumer interacts with our website through the use of third-party cookies.
Business Purposes
• Detecting and protecting against security incidents and fraudulent or illegal activities.
• Debugging to identify and repair errors on our website.
• Conducting website analytics in order to improve website performance and limit consumers’ experience on our website to local products and services.

Professional/Employment Information, such as professional background and work experience

• Direct from consumer when the consumer contacts us directly regarding employment opportunities, or to establish new business accounts.
• Third party service providers such as recruiting platforms that receive and process job applications.
Business Purposes
• Conducting hiring activities, including reviewing and interviewing job applicants and processing their applications.
• Performing regular business functions, verifying consumer information, accounting, approving new business accounts, and contracting with service providers to assist in these functions.

Inferences, such as preferred language, age-range, gender, product interests, etc.

• Direct from consumer when the consumer signs up for an account with us, contacts us by phone, email or webform, submits a product or service evaluation or complaint, or based on previous purchases or inquiries relating to our products or services.
• Automated collection when the consumer interacts with our website through the use of third-party cookies.
• Third party service providers such as website analytics providers. Business Purposes
• Tracking consumers’ online interactions and browsing history in order to better understand consumer interests and market trends.
Disclosure and Sale of Personal Information
In the last twelve (12) months, we have not sold personal information about you, but we have, at times, disclosed certain categories of personal information to third parties for business purposes.
We employ third party service providers to perform functions on our behalf that, from time to time, require us to disclose your information. Such functions may include, but are not limited to, securing our data and IT systems, processing payment and shipping information to complete consumer transactions, performing data analysis, and more. In some instances, we may also be required to disclose your personal information to comply with a legal obligation or governmental request, to detect and prevent fraud, to verify or enforce our Terms of Service or other applicable policies, or to otherwise protect the rights, property, safety or security of you, third parties, or the general public. Further details about the categories of your personal information, and the “business purposes” for which we disclose such categories, are set forth in the table below.
We may also allow third party partners and providers to collect certain of your information directly through our services, in order to optimize our services and business relationships, personalize online content on our website, and more.

Minors Under Age 16
Our website is not directed to, and we do not intentionally or knowingly collect the personal information of consumers less than 16 years of age. Furthermore, we do not and will not “sell” the personal information of consumers we know to be less than 16 years of age.

In the last twelve (12) months, we have disclosed for a business purpose the categories of personal information to the categories of third-party service providers, listed below. Please note, however, that whether or not we disclose your personal information and the nature of such potential disclosure (including the types of personal information disclosed, the business purposes involved, and the categories of recipients) depend on the nature of your relationship with us. Therefore, not all of the categories below may apply to you. If you wish to obtain further details about the disclosures of personal information which are specific to you, you may exercise your right to know, which is described in the section of this Privacy Policy entitled “Your California Privacy Rights.”

Category of Personal Information
Disclosures for a Business Purpose
&
Categories of Recipients
Identifiers ✓

website analytics/marketing providers
data security and IT support providers
internet and cloud service providers
Commercial Information ✓

website analytics/marketing providers
Internet/Network Information< ✓ data security and IT support providers website analytics/marketing providers Geolocation Data ✓ data security and IT support providers website analytics/marketing providers Your California Privacy Rights As a California resident, you may be able to exercise the following rights in relation to the personal information that we have collected about you (subject to certain limitations at law): The Right to Know You have the right to request any or all of the following information relating to the personal information we have collected about you or disclosed in the last twelve (12) months, upon verification of your identity: • The specific pieces of personal information we have collected about you; • The categories of personal information we have collected about you; • The categories of sources of the personal information we have collected about you; • The categories of personal information that we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; • The categories of personal information we have sold about you (if any), and the categories of third parties to whom this information was sold; and • The business or commercial purposes for collecting or, if applicable, selling personal information about you. The Right to Request Deletion You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions. The Right to Opt-Out of Personal Information Sales You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales. The Right to Non-Discrimination You have the right not to receive discriminatory treatment for exercising any of the rights described above. However, please note that if your exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), fulfilment of that right may mean that we are no longer able to provide you with our products or services or engage with you in the same manner. How to Exercise Your California Privacy Rights How To Exercise Your Right to Know or Right to Deletion To exercise your right to know and/or right to deletion, please submit a request by: · Emailing: with the subject line “California Rights Request,” or · Calling: 877-779-3389 We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the personal information collected in connection with a request to exercise the right to know and/or right to deletion, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity How To Exercise Your Right to Opt-Out of Personal Information Sales As explained above, we do not currently sell your personal information to third parties. However, if at any point we begin selling personal information to third parties for monetary or other valuable consideration (a change which will be reflected in this Privacy Policy), then we will provide you with a right to opt-out of such sales. Authorized Agent In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (a) you provide sufficient evidence to demonstrate that the requestor is an authorized agent, by directly confirming that with us or by providing us with your signed written permission or a power of attorney; or (b) you successfully verify your own identity with us. “Shine the Light” California’s “Shine the Light” law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of personal information to third parties for their direct marketing purposes. At this time, we do not disclose your personal information to third parties for their direct marketing purposes, as defined by the Shine the Light law Financial Incentives We currently offer the following financial incentives in exchange for the collection of certain personal information: · Discount for Online Newsletter Subscription: If you opt-in to receive our online newsletter service by providing us with your email address for that purpose, we will send you a regular email newsletter that includes promotions and occasional discounts. We require your name or alias and email address in order for us to send you our newsletter. You can unsubscribe from our newsletter at any time by clicking on the unsubscribe link provided at the bottom of each newsletter. · First-Time Purchase Discount: We offer a discount code for first-time purchases. If you wish to make use of such discount, you will need to create an account with us in order for us to verify that you are a first-time customer and are therefore eligible for the discount. This will require you to provide us with certain identifiers, including your name, address, email and telephone number. In addition, you will need to complete a first-time purchase (which will require you to enter additional transaction information, including your payment, shipping and billing details). All the personal information we collect from you for purposes of this discount is necessary to enable its utilization by first-time customers. At any time after using the discount (or before, if you wish to forfeit such discount), you are able to delete your account and/or submit a request to exercise your right to deletion of your personal information. Updates to This Privacy Policy We will update this Privacy Policy from time to time. When we make changes to this Privacy Policy, we will change the “Last Updated” date at the beginning of this Privacy Policy. If we make material changes to this Privacy Policy, we will provide you with notice to the extent required by law, including notice to your registered email address, prominent posting on our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification. Contact Us If you have any questions or requests in connection with this Notice or other privacy-related matters, please send an email to . Alternatively, inquiries may be addressed to: Mutual Trading Co., Inc. Customer Service 4200 Shirley Ave., El Monte, CA 91731 TEL (213) 626-9458

WSET Policies

Sake School of America Inc., being a WSET Approved Programme Provider, the Sake School of America Inc. uses WSET candidates’ data (name, email, address, DOB, supporting information for Reasonable Adjustment or Special Consideration requests) are shared with WSET and will be handled under WSET’s Privacy & Date Protection Policy.

Complaints

Sake School of America is committed to providing a learning and working environment in which complaints are responded to promptly and with minimum distress to all parties. Sake School of America is committed to a visible, accessible, and fair complaints process. Sake School of America views student complaints as providing an opportunity to review and improve its policies and practices and also to gain insight into student levels of satisfaction.

Scope:
This policy applies to student complaints made in the context of Sake School of America’s provision of WSET® Courses and Examinations as a WSET® Approved Program Provider.

Definitions:
What is a complaint?
A complaint is a formal statement expressing dissatisfaction that requires action or response. The complaint may be in relation to any aspect of the course delivery, conduct of teaching staff or management, or matters pertaining to the examination process or content. Where the complaint is regarding a possible incorrect examination result, Sake School of America will provide students with appropriate information regarding the WSET® Enquiry and Appeals Process.

Policy:
Sake School of America’s procedures for handling student complaints are based on confidentiality, impartiality, procedural fairness, and prompt resolution. Where complaints are of a minor nature, they may be resolved informally. An informal approach is appropriate when it can be achieved. But if concerns cannot be satisfactorily resolved informally, then the formal complaints procedure should be followed. The formal complaints procedure is intended to ensure that all complaints are handled fairly and consistently. All formal complaints must be
submitted in writing, via email, or written correspondence. All formal complaints will receive a written response of the outcome of the complaint, following appropriate investigation of the circumstances.

Sake School of America: info@sakeschoolofamerica.com
843 East 4th St, Los Angeles, CA 90013. https://www.sakeschoolofamerica.com/

Responsibilities:

  1. Sake School of America’s responsibilities will be to:
    1. acknowledge any formal complaint received in writing within ten working days
    1. respond within a stated period of time of 21 working days with either a conclusion or a further update depending on the severity of the complaint
    1. deal reasonably and sensitively with the complainant
    1. cooperate fully in any investigation process
    1. take action where appropriate, including any corrective action necessary to prevent recurrence; if the complaint relates to examination content or results, provide the student with the relevant WSET® guidance notes and forms to allow the student to utilize the WSET® Enquiries and Appeals process
  2. A complainant’s responsibility is to:
    1. bring their complaint, in writing, to Sake School of America’s attention within seven working days of the issue arising or within seven days of completion of the course or examination;
    1. explain the problem as clearly and as fully as possible with your expected outcome;
    1. allow Sake School of America a reasonable time to deal with the matter
    1. recognize that some circumstances may be beyond Sake School of America’s control

Outcomes:
Students will receive written advice on the outcome of their complaints. Some of the possible outcomes of a student complaint include:

  • Through the resolution process, the student gains a better understanding of the situation so that their concerns are addressed.
  • A mutually acceptable resolution is reached through conciliation or mediation.
  • The student receives an apology, and/or the issue or behavior that was the basis of their complaint is modified. In some cases, the complaint cannot be substantiated, and no further action will result.

Referral to WSET:
If the above steps have all been completed and the student is still dissatisfied, they can file a complaint with the WSET. Please note that the WSET can only take action on complaints from students if they have followed the above procedures first. email QA@wsetglobal.com 

Confidentiality & Documentation:
All documentation relating to complaints will be kept strictly confidential and will not be accessible to anyone who is not directly involved in handling the complaint. Any material about the outcome of the complaint will be placed on the appropriate student file. A register of complaints made (anonymous of names), along with their outcomes, will be maintained to continuously improve policies and practices.

Conflict of Interest Policy

As an APP Sake School of America is required to identify to WSET and assist in managing or monitoring actual, potential, and perceived conflicts of interest (‘Conflicts of Interest’) involving both APP staff and students. This policy complements WSET’s conflicts of interest policy and works to safeguard the integrity of WSET qualifications and promote confidence in WSET and Sake School of America processes and procedures.

This policy applies to all Sake School of America staff and students and to any individual acting on behalf of [Sake School of America].

A Conflict of Interest exists where an individual has interests or loyalties that could adversely influence their judgement, objectivity or loyalty to WSET or Sake School of America when conducting activities associated with WSET qualifications.

Examples of Conflicts of Interest include:

• The assessment of candidates by an individual who has a personal interest in the result of the assessment for any or all individuals concerned;

• The moderation of assessment of candidates by an individual who has a personal interest in the result of the assessment for any or all individuals concerned;

• The undertaking of a WSET qualification by any individual employed by an APP;

• The invigilation of a WSET assessment by any individual involved in the delivery of training leading to the assessment;

• The coaching of candidates by any individual involved in the assessment of candidate scripts;

• The employment by an APP of individuals engaged in the delivery of taught programmes or in the role of Internal Assessor in another APP;

• The investigation of a non-compliance incident by someone who is unable to act impartially.

Some of these Conflicts of Interest are manageable and therefore acceptable. For example, if family member of one of Sake School of America’s educators or APP staff takes a qualification and exam through Sake School of America, or when an employee of Sake School of America, or of the WSET, takes a WSET qualification through Sake School of America, we can notify WSET in advance and work with them to put in place measures to maintain the integrity of the exam.

Some Conflicts of Interest are not manageable and are not acceptable. For example, no mitigation efforts overcome the conflict created when an individual when a single individual serves as the educator and exam officer of an exam for a family member where an external invigilator is not available.

Any staff member or student of Sake School of America who becomes aware of a Conflict of Interest must inform Toshio Ueno info@sakeschoolofamerica.com as soon as possible. Toshio Ueno will inform the WSET of the possible conflict of interest and will work with WSET to put any protective or mitigating measures in place to manage the conflict on a case-by-case basis. If WSET and Sake School of America determine the conflict is not manageable, Toshio Ueno will inform any impacted APP staff or students.

Please note that the failure to declare a conflict of interest may have consequences for the student or Sake School of America because we are required to report conflicts to WSET.

Reasonable Adjustments Policy

Both WSET and Sake School of America want to make WSET assessments accessible for all students, so none are at an advantage or disadvantage based on a disability or differing ability. This policy and the reasonable adjustment process allows us Sake School of America to work with you, our student, before an assessment to gather the information we need to submit a request to WSET and work with them to make arrangements that give students access to WSET qualifications.

A reasonable adjustment is any accommodation or arrangement that helps to reduce the effect of a known disability or difficulty that substantially disadvantages a student’s assessment. Using a reasonable adjustment does not impact how WSET grades your exam, or your result, but WSET cannot agree to reasonable adjustments where your particular difficulty directly affects performance necessary to complete the assessment outcomes (e.g. inability to smell or taste for a Level 3 Exam). The goal of a reasonable adjustment is to give you equal access to a WSET qualification, not to give unfair advantages over other students who take an assessment without the same adjustment, or to affect the overall reliability of the assessment outcomes that are explained in the course Specification.

Examples of reasonable adjustments may be:

• Changing standard assessment arrangements, for example allowing candidates extra time to complete the assessment activity;

• Adapting assessment materials, such as providing materials in large text format;

• Providing access facilitators during assessment, such as a sign language interpreter or reader;

• Re-organising the assessment room, such as removal of visual stimuli for an autistic candidate.

Sake School of America will gather the information we need from you to submit a Reasonable Adjustment Application form to WSET. WSET must approve and arrange reasonable adjustments before the assessment activity takes place. Before completing enrolment with [Sake School of America], we will give all students access to this policy and the chance to identify any special needs that could require a reasonable adjustment. If a student identifies a special need, [Sake School of America] will give the student the Reasonable Adjustment Application form as soon as possible and work with the student to gather the necessary information.

For any student seeking a reasonable adjustment, please contact Toshio Ueno info@sakeschoolofamerica.com with:

• Your full name;

• contact information;

• description of the special need, disability or differing ability that requires an adjustment; and

• supporting documentation.

You must submit this information at least 30 working days before the exam date for Levels 1-3 qualifications and at least 40 working days before the exam date for Level 4 Diploma. The information you submit will be shared with WSET and will be handled under WSET’s Privacy and Data Protection Policy.

Sake School of America will keep records of all reasonable adjustment applications.

Special Consideration Policy

Special consideration is any adjustment given to a student who has temporarily experienced an illness or injury, or other event outside of their control at the time of the exam that significantly affects their ability to take the exam or their ability to show their knowledge and understanding in the assessment. Special consideration is only for things that happen immediately before or during an exam that have a material impact on your, the student’s, ability to take the exam or on your performance. To be eligible for special consideration, you must have completed the whole course and would have been fully prepared if not for the temporary illness, injury or other uncontrollable event. A special consideration may be for an individual (e.g. a student becomes ill the day of the exam) or a group of students (e.g. an exam is interrupted by a natural disaster).

You may be eligible for special consideration if:

• Your performance on the exam is adversely affected by an event outside of your control. This may include temporary illness, temporary injury, bereavement or exam room conditions;

• Reasonable adjustments which were agreed in advance of the exam proved inappropriate or inadequate;

• The application of special consideration would not make a passing result and certificate misleading about the student’s ability to satisfy the qualification’s assessment criteria.

Applying for special consideration

If you have taken an exam, or your exam is immediately approaching, and you feel that you have a temporary injury or illness, or other uncontrollable event that has interfered with your ability to complete your exam, please contact Toshio Ueno info@sakeschoolofamerica.com as soon as possible. Sake School of America will provide you with a Special Consideration Application Form, which must be completed and returned with supporting documentation within 5 working days after the effected exam. The information you submit will be shared with WSET and will be handled under WSET’s Privacy and Data Protection Policy.

If there has been serious disruption during an exam affecting a group of students, Sake School of America will submit a detailed report of the circumstances and candidates affected to WSET to request a special consideration.

Sake School of America will keep records of all applications for special consideration.

Malpractice and Maladministration Policy

Both Sake School of America and WSET have policies and procedures in place to protect WSET students and safeguard the integrity of WSET qualifications. Sake School of America ensures compliance with Sake School of America and WSET’s policies through this Malpractice and Maladministration Policy, which gives a framework for both us and you to identify, report and manage potential malpractice or maladministration.

Non-compliance with Sake School of America or WSET Policies and Procedures can fall into two distinct, but related, categories:

  1. Maladministration, where the non-compliance is generally unintentional, or the result of mistakes, carelessness, inexperience or poor processes; and

2.    Malpractice where the non-compliance is intentional or the result of a negligent or reckless action without consideration of the consequences of the action.

Context is important and the line between maladministration or malpractice is not always clear: for example, maladministration incidents may become malpractice (e.g. if you fail to implement corrective measures, repeat the same or similar incident, or attempt to misrepresent or hide information during an investigation); or there may be mitigating factors that turn potential malpractice into maladministration. Though malpractice and maladministration are distinct concepts, they can shade into one another. Malpractice and maladministration are always case, context and fact specific. Both APPs and students can commit malpractice and maladministration.

There are many ways that malpractice or maladministration could occur, including new ways we have not seen yet. But some examples of malpractice or maladministration include:

For APPs:

  • Failure to adhere to WSET Policies and Procedures;
  • Failure to follow WSET requirements for course delivery or exam regulations;
  • Failure to follow WSET’s candidate registration and certification procedures;
  • Late student registrations;
  • Fraudulent claim for certificates/fraudulent use of certificates/reproduction or forgery of certificates;
  • Withholding critical information from WSET quality assurance;
  • Insecure storage of exam materials;
  • Revealing or sharing confidential exam materials with candidates ahead of an exam;
  • Intentional attempts to manipulate exam results so that they do not reflect the candidate’s actual exam performance;
  • Issue of incorrect exam results/failure to issue results to students in a timely manner;
  • Failure to timely respond to WSET;
  • Unauthorized reading/amendment/copying/distribution of exam papers;
  • Failure to report changes in APP ownership/personnel/location/facilities;
  • Denying WSET access to information, documentation, workforce, facilities;
  • Failure to return exam papers within the specified timeframe or to follow delivery and tracking regulations;
  • Infringements of WSET copyright, trademarks, intellectual property rights and brand identity;
  • Use of unqualified and/or unregistered educators or internal assessors;
  • Breach of confidentiality
  • Misleading advertising/publicity;
  • Any action likely to lead to an adverse effect.
  • Failure to disclose a Conflict of Interest;

For students:

  • Cheating, or facilitating cheating, including the use of unauthorised devices or materials;
  • Disruptive behaviour in an exam;
  • Plagiarism of any nature by students;
  • Impersonation (including forgery of signatures);
  • Unauthorised reading/amendment/copying/distribution of exam papers;
  • Any action likely to lead to an adverse effect;
  • Breach of confidentiality.

In general, we also expect that both Sake School of America staff and our students should treat others and be treated professionally and respectfully at all times. We will treat inappropriate behaviour including verbal or physical abuse, persistent or unrealistic demands, or threats that cause stress to staff as misconduct and may report student misconduct to WSET as necessary.

Reporting and Investigation of Malpractice or Maladministration

As an APP, we aim to ensure compliance with WSET Policies and Sake School of America policies and will keep records of potential or actual malpractice or maladministration by you, our students, or our staff.

We are required to notify WSET immediately of any non-compliance issues that could be malpractice or maladministration, so that WSET can investigate the non-compliance under their own Malpractice and Maladministration Policy.

We ask that you also raise any concerns or non-compliance issues that may be malpractice or maladministration with Sake School of America as soon as possible by following the process outlined in our Complaints policy.

During WSET’s investigation, they may reach out to Sake School of America or to you directly to request further information or conduct an interview. Please respond to any requests promptly and honestly.

Managing Non-Compliance

If WSET identifies malpractice or maladministration, they will consider its impact and may apply sanctions. WSET will take all reasonable steps to ensure the sanctions do not disadvantage uninvolved students affected by malpractice or maladministration. However, in some cases, they may need to disallow or withhold results and/or certificates.

Potential sanctions may include: Written Warning, Training, Action Plan, and use of Independent Verifiers/Observers/Assessors/Invigilators.

WSET will consider all relevant information on a case-by-case basis, balancing the facts with potential or actual effects, and against the seriousness of the sanctions against those effects. WSET records all malpractice and maladministration incidents for both APPs and students. If WSET determines that a student has committed malpractice or maladministration, they may apply one or any of the following sanctions:

Appeals

If you wish to appeal penalties or sanctions WSET has imposed due to Malpractice or Maladministration, please follow the procedures laid out in WSET’s Complaints Policy.

Diversity and Equality Policy

Sake School of America is committed to upholding the principles of diversity and equality in all areas of its work, seeking to ensure that all students and other stakeholders are always treated fairly and equally.
Sake School of America assures equality of opportunity for students by:

  • Promoting open access to all of our qualifications on offer (having regard to the legal minimum age for the retail purchase of alcohol and assessment competence standards);
  • Allowing students with special educational needs, disabilities, or temporary injuries to access  assessments without changing the demands of the assessment in line with our Reasonable Adjustment and Special Consideration policies;
  • Ensuring that this policy is considered during the development of new qualifications and;
  • To have a diversity and equality policy in place which promotes open access to our qualifications;
  • Inviting feedback on diversity issues from students and other stakeholders;
  • Working with relevant organizations as appropriate to develop measures to identify and prevent inequality of opportunity; and
  • Review this policy regularly to ensure it meets legislative and organizational requirements and is fit for purpose.

Sake School of America assures equality of opportunity by considering applications from any organization or individual who can demonstrate that they meet our approval criteria.

Sake School of America : info@sakeschoolofamerica.com