30th December 2020
In the transitional period ending on the 31st December 2020, the Nasstar Group of companies and all its operating divisions, including Modality, were working hard to assess and mitigate the likely impact of ‘Brexit’ on its customers and suppliers under a variety of potential outcomes.
This update is provided to give information to our customers and partners.
Background
We are a UK registered business, headquartered in the UK and with our operations predominantly based in the UK.
Focus areas and Nasstar Group’s Response
We are committed to ensuring a continued reliable service in 2021.
We identified two key focus areas for a potential ‘Brexit’ impact, being:
- Receiving personal data from the EEA
- Supply chain continuity
Receiving personal data from the EEA
Most of our customers are in the UK and will be contracted with a UK entity in the Nasstar Group.
However, for EEA customers and for UK customers who contract for the benefit of other customer group members in the EEA, there was a concern that additional measures would be required to protect the transfer of personal data to the UK following 31st December 2020.
Further to the trade and cooperation agreement which was reached between the UK and the EU on 24th December 2020, businesses have a period of grace in so far as the agreement includes an interim provision (a bridging mechanism) for transmission of personal data to the UK. This is for four months from the agreement entering into force, extended by two months unless one of the parties objects, or, if earlier, until there is an adequacy finding for the UK. Personal data transfers from the EEA to the UK can therefore continue for the time being without the need for additional safeguards.
In preparedness for a hard Brexit, working with our external privacy advisers we had prepared a set of international transfer terms (incorporating the Standard Contractual Clauses) for incorporation into our contracts with affected customers to enable personal data originating from the EEA to continue to flow to us in the UK.
Hopefully, these shan’t be needed, and the UK will be recognised as an adequate territory by the EU before the interim provision ends. However, we remain prepared for the unlikely. If you have any remaining concerns, please get in touch with your Account Manager or contact enquiries@nasstar.com
Supply Chain
We have taken measures and made changes to our Supply Chain where necessary in anticipation of the various possible outcomes and as a result, we anticipate that our business can continue much as it is today. However, we recognise there may be some issues and delays caused by increased lead times, transit times and processing complexities.
We would like to advise our customers and partners of the following key points:
As it stands, the Procurement teams will be looking to manage quotes and orders based on our optimal supply chain routes. However, we are expecting:
- Initial delays to inbound vendor shipments travelling into the UK via mainland Europe as the supply chain adjusts to a new normal.
- Additional requests for Nasstar/Modality to export products on behalf of our customers who wish to continue to supply products into the EU.
- Increased demand on our Builds function in Poole for customers wishing to limit bringing goods into their own facilities prior to them being exported, thus using Nasstar as their own export agent.
- Price increases on a very small number of products we currently supply, if imports from the EU are subject to WTO terms.
- Any open or new orders after 31st December 2020 fall under the new legislature and could have additional duties, taxes, and licencing requirements that may increase costs or delay deliveries.
- Any orders that are not following the optimal supply chain outlined, may require additional clarifications such as what freight services are needed, and who will be acting as the Importer Of Record at the end country in the case that there is a trade border.
Based on the information from our Logistics suppliers, we are anticipating potential delays for goods entering the UK from the EU, or goods leaving the UK for EU destinations, for both standard shipping services and priority services. We are therefore unable to accurately quote lead times for goods entering the UK from the EU, or goods leaving the UK for EU destinations.
Given the current uncertainty, it may be necessary to implement further specific measures in the near future. As the circumstances progress, we will continue to update you and keep you informed as we receive any confirmation of the Brexit position.
Summary
Based on the operating model for Nasstar's Group of Companies (including Modality) we do not expect significant impacts on our business or service provided to our customers. We will however continue to pay close attention to the situation, and take appropriate action where required.