Ethics & Compliance

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Ethics and Compliance

At Votorantim Cimentos, we are committed to customer success, empowered employees, sustainability and operational excellence. We also know that our success in these areas will only be achieved if we act ethically with integrity and transparency. That's why our Values and Beliefs and Code of Conduct reinforce our company wide commitment to Compliance. We expect employees at all levels, from operational roles to our board of directors, and shareholders to follow the Code of Conduct guidelines and to comply with all laws, regulations and policies in the regions and countries where we operate. We are constantly searching for best practices, encouraging the fight against corruption and emphasizing the damages caused by corruption in political, economic and social domains.

At Votorantim Cimentos, we have zero tolerance towards corruption, bribery and facilitation payments. We prohibit the offer or receipt of any kind of advantages meant to secure an unfair business or personal gain, especially with regard to public officials or government authorities. This includes receiving and offering gifts, providing entertainment and hospitality, extending corporate invitations or any other act that is in conflict with local laws and regulations or is contrary to our own policies. Effective in 2017, Votorantim Cimentos has had in place a Donations and Sponsorship policy that restricts and governs political donations. In all instances, employees of Votorantim Cimentos are expected to respect and abide by the guidelines outlined in our Code of Conduct.

Our programs and policies are constantly evolving as we consolidate best practices and adapt to changes in our society, while preserving our enduring legacy of integrity, ethics and transparency.

Compliance Program

Since 2013 we have maintained a Compliance Program with communication and training campaigns aimed at all employees at all levels within the Company. We monitor the effectiveness of the program regularly, and take the necessary measures in the event of infractions, intentional or unintentional. We also encourage the reporting of any suspected wrong doing through our Ethics Line.

Ethics Line

Our Ethics Line —public and open to all, inside and outside of the organization—provides a way to report misconduct (real or perceived) in a confidential and anonymous manner. All reports are investigated and addressed in accordance with internal policies and current laws and regulations and we do not tolerate any form of retaliation against those who raise these concerns.

1. People who enter this website; have been informed about the recording, processing, transfer, deletion, destruction and anonymization of their personal data and sensitive personal data for the purposes described below and acknowledged thereto.

2. This information is made in accordance with the provisions of the enlightenment liability of the Data Controller, as set out in Article 10 of the Law on Protection of Personal Data No. 6698.

3. Recording of Your Personal Data : Your personal data listed below are recorded in the personal data inventory as specified in our personal data policy.

3.1 IP number,
3.2 Location information,
3.3 Date and time information,
3.4 Device information,
3.5 Browser information,
3.6 Language information,
3.7 Country information,
3.8 City information,
3.9 Information of source location,
3.10 Operating system information,
3.11 Service provider information,
3.12 Display resolution information,
3.13 Pages visited,
3.14 Time spent on pages visited,
3.15 Acquisition information,
3.16 Behavioral information,
3.17 Transformation information,
3.18 Age information as reported by the referrer,
3.19 Gender information as reported by the referrer,
3.20 In-site search information

4. How are your personal data obtained and recorded? Your visitor information on the website are obtained through google analytics, social media, digital marketing channels and similar software and recorded.

5. Processing of your personal data: In this context, your personal data is processed by special software for the following purposes:

5.1 Protecting the security of life and property of those within the organization,
5.2 Sharing evidence with the institutions authorized by law, with the courts and with the prosecution offices, in case of violations of relevant legislations, primarily the Turkish Penal Code, Law of Misdemeanor, Code of Obligations, Turkish Commercial Code, Labor Law, Law No. 5651 and Law No. 5549 on Prevention of Laundering of Proceeds of Crime Revenues,
5.3 Identification, investigation and prevention of internal Company policy violations or standard violations,
5.4 Managing and conducting services regarding the principal business activity of the Company,
5.5 Fulfillment of the contractual obligations of the Company,
5.6 Centralization of data,
5.7 Developing the services in the company and on the website by analyzing the data.

6. Deletion, Destruction and Anonymization of Personal Data : These data in our personal data inventory shall be deleted, as stipulated in our Personal Data Protection Policy, until the end of the working hours 10 years after the last day of the calendar year in which your visit record to your company website is registered.

7. Transfer of your personal data : Personal data related to your company visit register may be transferred to the following persons and organizations.

7.1 Law enforcement offices,
7.2 Courts,
7.3 The prosecution offices,
7.4 Institutions authorized by law,
7.5 Lawyers working in the company or contracted institution lawyers,
7.6 Board of directors and executive board of the Company,
7.7 Inspection Board of the Company,
7.8 Administrative unit management of the Company,
7.9 Information Technology Department of the Company,
7.10 Sales and Marketing Department of the Company,
7.11 Private information security company management,
7.12 Senior management of the Company abroad.

8. Security of Your Personal Data : As stated in the Information Security Policy, the Company takes all technical and administrative measures to ensure the appropriate level of security for the issues stated below when conducting personal data processing activities.

8.1 To prevent unlawful processing of the personal data,
8.2 To prevent unlawful access to the personal data,
8.3 To maintain protection of the personal data.

9. Your rights : To the extent your data is processed by the Company and the Company processes your data in the capacity of the data controller, you possess the following rights in respect of your personal data:

9.1 To learn whether any of your personal data is processed or not;
9.2 To request information regarding the processing activities of your personal data;
9.3 To learn the purposes of processing of your personal data;
9.4 To learn these persons in case your personal data is transferred to third parties within the country or abroad;
9.5 To request correction of personal data if incompletely or incorrectly processed;
9.6 To request the deletion or destruction of personal data in case the reasons that require the processing of personal data are disappeared or the Company has no legal basis or legitimate interest in order to process such data;
9.7 To require the Company to ensure that third parties authorized by the Company and processing personal data to respect your rights under this section;
9.8 To appeal against the disadvantageous results that might generate due to processing of personal data by automated systems;
9.9 To request compensation of damages in case you incur losses due to unlawful processing of your personal data.

10. Data Controller Information : As the COMPANY whose detailed corporate information is issued below, we, as and in the capacity of Data Controller, will use your personal data in accordance with the relevant legislation pursuant to the Law on Protection of Personal Data No. 6698.

11. Procedure for Application to the Data Controller : Pursuant to the first paragraph of Article 13 of the Law on the Protection of Personal Data No. 6698; the applications to be made to our Company, which is the data controller, regarding these rights must be communicated in writing or by other methods determined by the Personal Data Protection Board. In this context, the applications to be submitted to our Company “in writing” can be made as follows:

11.1 By in person application of the applicant,
11.2 Through the Notary Public,
11.3 By sending to the registered e-mail address of the Company as signed with the “secure electronic signature” defined in the Electronic Signature Law No. 5070,
11.4 By an e-mail to be sent to the e-mail address of the data controller representative of the company,
11.5 By a signed mail or cargo to be sent to the physical mailing address of the companies.

Titles
VOTORANTİM ÇİMENTO SANAYİ ve TİCARET A.Ş.
YİBİTAŞ YOZGAT İŞÇİ BİRLİĞİ İNŞAAT MALZEMELERİ TİCARET ve SANAYİ A.Ş.
VOTORANTİM NAKLİYECİLİK TİCARET ve SANAYİ A.Ş.

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