Data Protection Policy
We take data protection and confidentiality very seriously and adhere to the provisions of the applicable data protection regulations. Please read this data protection information carefully before submitting a report.
Purpose of the whistleblowing system and legal basis
The whistleblowing system (BKMS® System) serves the purpose of securely and confidentially receiving, processing and managing reports regarding violations of the Vallourec Code of Ethics, internal policies, standards and procedures, laws and regulations. The processing of personal data in the BKMS® System is based on the legitimate interests of our company to detect and prevent misconduct.
Responsible authority
The party responsible for data protection in the whistleblowing system is
- Vallourec Tubes and
- its subsidiaries
as parties with mutually autonomous responsibility (hereafter also: “Vallourec”). The reporting system is operated by a specialised company, EQS Group GmbH, Bayreuther Str. 35, 10789 Berlin in Germany, on behalf of Vallourec.
Personal data and information entered into the reporting system are stored in a database operated by EQS Group GmbH in a high-security data centre. Only Vallourec has access to the data. EQS Group GmbH and other third parties do not have access to the data. This is ensured in the certified procedure through extensive technical and organisational measures.
All data are stored encrypted with multiple levels of password protection so that access is restricted to a very small selection of expressly authorised persons at Vallourec.
Questions on data protection can be sent to the Chief Ethics and Compliance Officer at the following email address: ethics.compliance@vallourec.com
Type of the collected personal data
Use of the reporting system takes place on a voluntary basis. If you submit a report via the whistleblowing system, we collect the following personal data and information:
- your name, if you choose to reveal your identity,
- whether you are employed at Vallourec, and
- the names of persons and other personal data of persons that you name in your report.
Confidential handling of reports
Incoming reports are received by a small selection of expressly authorised and specially trained employees of Vallourec and are always handled confidentially. These employees of Vallourec will evaluate the matter and perform any further investigation required by the specific case.
During the processing of a report or the conduction of a special investigation, it may become necessary to share reports with additional employees of Vallourec. The latter may be based in countries outside the European Union or the European Economic Area with different regulations concerning the protection of personal data. We always ensure that the applicable data protection regulations are complied with when sharing reports.
All persons who receive access to the data are obligated to maintain confidentiality.
Information of the accused person
As a basic principle we are bound by law to inform the accused persons that we have received a report concerning them, unless this threatens further investigations into the report. In doing so, your identity as whistleblower is not revealed as far as is legally possible.
Rights of the data subjects
According to applicable data protection law, you and the persons named in the report have the right to inquiry, rectification, erasure, restriction of processing and the right to object to processing of personal data concerning them. If the right of objection is claimed, we will immediately examine to what extent the stored data is still necessary for the processing of a report. Data that is no longer required is deleted immediately. In addition, you have the right to lodge a complaint with a supervisory authority.
Retention period of personal data
Personal data is retained for as long as necessary to clarify the situation and perform an evaluation of the report or a legitimate interest of the company exists or it is required by applicable law. After the report processing is concluded, this data is deleted in accordance with the statutory requirements.
Use of the reporting portal
Communication between your computer and the reporting system takes place over an encrypted connection (SSL). Your IP address will not be stored during your use of the reporting system. In order to maintain the connection between your computer and the BKMS® System, a cookie is stored on your computer that merely contains the session ID (a so-called null cookie). This cookie is only valid until the end of your session and expires when you close your browser.
It is possible to set up a postbox within the reporting system that is secured with an individually chosen pseudonym/user name and password. This allows you to send reports to the responsible employee at Vallourec either by name or in an anonymous, safe way. This system only stores data inside the reporting system, which makes it particularly secure. It is not a form of regular e-mail communication.
Note on sending attachments
When submitting a report or an addition, you can simultaneously send attachments to the responsible employee of Vallourec. If you wish to submit an anonymous report, please take note of the following security advice: Files can contain hidden personal data that could compromise your anonymity. Remove this data before sending. If you are unable to remove this data or are unsure how to do so, copy the text of your attachment into your report text or send the printed document anonymously to the address listed in the footer, citing the reference number received at the end of the reporting process.
Version: 05 March 2018